Cite as: 535 U. S. 43 (2002)
Opinion of the Court
unaware of the debt until the return was filed, the IRS would have had only two years to act before the debt became dischargeable in bankruptcy. For these reasons, petitioners believe the lookback period is not a limitations period, but rather a definition of dischargeable taxes.
We disagree. In the sense in which petitioners use the term, all limitations periods are "substantive": They define a subset of claims eligible for certain remedies. And the lookback is not distinctively "substantive" merely because it commences on a date that may precede the date when the IRS discovers its claim. There is nothing unusual about a statute of limitations that commences when the claimant has a complete and present cause of action, whether or not he is aware of it. See 1 C. Corman, Limitation of Actions § 6.1, pp. 370, 378 (1991); 2 Wood, supra, § 276c(1), at 1411. As for petitioners' reliance on § 523(a)(1)(B)(ii), that section proves, at most, that Congress put different limitations periods on different kinds of tax debts. All tax debts falling within the terms of the three-year lookback period are nondischargeable in bankruptcy. §§ 523(a)(1)(A), 507(a)(8)(A)(i). Even if a tax debt falls outside the terms of the lookback period, it is nonetheless nondischargeable if it pertains to an untimely return filed within two years before the bankruptcy petition. § 523(a)(1)(B)(ii). These provisions are complementary; they do not suggest that the lookback period is something other than a limitations period.
B
It is hornbook law that limitations periods are "customarily subject to 'equitable tolling,' " Irwin v. Department of Veterans Affairs, 498 U. S. 89, 95 (1990), unless tolling would be "inconsistent with the text of the relevant statute," United States v. Beggerly, 524 U. S. 38, 48 (1998). See also American Pipe & Constr. Co. v. Utah, 414 U. S. 538, 558-559 (1974); Holmberg v. Armbrecht, 327 U. S. 392, 397 (1946); Bailey v. Glover, 21 Wall. 342, 349-350 (1875). Congress must be presumed to draft limitations periods in light of this back-
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