Supreme Court of the United States
Young v. United States
March 4, 2002535 U.S. 43
Summary
Justice Scalia delivered the unanimous opinion holding that the Bankruptcy Code’s three-year lookback period for priority and nondischargeability of certain tax debts is equitably tolled during a prior bankruptcy proceeding. The automatic stay prevented the IRS from protecting its claim, and tolling applied regardless of whether the debtors filed the earlier petition in good faith or to exhaust the lookback period. The Code’s express tolling provisions elsewhere did not preclude equitable tolling. The Court affirmed the First Circuit’s judgment that the Youngs’ tax debt had not been discharged. There were no separate opinions.
Holding
- Whether the three-year lookback period is equitably tolled during a prior bankruptcy proceeding.. The three-year lookback period under 11 U.S.C. § 507(a)(8)(A)(i) is a limitations period and is tolled during the pendency of a prior bankruptcy petition.
- Whether equitable tolling depends on the debtors’ intentions when filing successive petitions.. Tolling applies whether the prior petition was filed in good faith or solely to run down the lookback period.
Docket 00-1567
Cited authorities
- 11 U.S.C. §§ 523
- 26 U.S.C. § 6502
- 11 U.S.C. § 507(a)(8)(A)(i)
- 26 U.S.C. § 6331
- 11 U.S.C. § 1307
- 26 U.S.C. §§6501
- 26 C.F.R. § 301.7122
Cited by
- Doe v. Siddig
- In Re International Gospel Party Boosting Jesus Groups, Inc., Debtor
- In Re Robert J. Spenlinhauer, Debtor
- United States v. Seeley
- Asplundh Tree Expert Co. v. William J. Abshire James P. Allison Teresa Amos Joyce Anayanwa Johnnie W. Andress, Jr…
- Audrey Marie Hall, Petitioner v. Commissioner of Internal Revenue, Respondent
- Buffets, LLC v. California Franchise Tax Board
- In Re Paul Valente, Debtor Fleet National Bank, Appellant v. Paul Valente, Appellee