Observing that the case law surrounding the issue was “scarce,” a Pennsylvania bankruptcy court has held that the section of the Bankruptcy Code which tolls statutes of limitation upon the filing of bankruptcy petitions, 11 U.S.C.A. 108(a), may be invoked by Chapter 13 debtors-in-possession prosecuting actions that constitute estate property. Although the issue was less clear than in the Chapter 11 context, the court found no reason why 108 should not also apply to Chapter 13 debtors-in-possession, as the debtor is the representative of the estate in prosecuting the action. The debtor in a Chapter 13 case has the ability to sue on behalf of the estate, and essentially “steps into the role of the trustee” when doing so, the court reasoned. Hence, the debtor is eligible for the same provisions of the Code affecting the trustee’s power to sue, including the extension of time provisions in 108. A split of authority was noted