Page:Arellano v. McDonough.pdf/14

Rh Finally, Arellano contends that “the ‘nature of the underlying subject matter’ ”—veterans’ benefits—counsels in favor of tolling here. Brief for Petitioner 33–34. To support this proposition, he invokes Brockamp, which considered whether courts can equitably toll time limits for filing tax-refund claims. 519 U. S., at 348. After holding that the statute’s text and structure rebutted the Irwin presumption, we observed that the “nature of the underlying subject matter—tax collection—underscore[d] the linguistic point.” Brockamp, 519 U. S., at 352. “Tax law, after all, is not normally characterized by case-specific exceptions reflecting individualized equities.” Ibid. By contrast, Arellano argues, providing benefits to veterans is a context in which individualized equities are paramount. See King v. St. Vincent’s Hospital, 502 U. S. 215, 220, n. 9 (1991) (“[P]rovisions for benefits to members of the Armed Services are to be construed in the beneficiaries’ favor”).

If the text and structure favored Arellano, the nature of the subject matter would garnish an already solid argument. But the nature of the subject matter cannot overcome text and structure that foreclose equitable tolling. Brockamp turned to the “nature of the underlying subject matter” only to “underscor[e] the linguistic point.” 519 U. S., at 352. Arellano, however, lacks the linguistic point. This is not a case in which competing interpretations are equally plausible; it is one in which Congress’s choice is evident.

We hold that §5110(b)(1) is not subject to equitable tolling and affirm the judgment of the Court of Appeals.

It is so ordered.