In Kiehn v. Nelsen's Tire Co., 45 Wn. App. 291, 724 P.2d 434 (1986), the Court of Appeals held that suit was not commenced against Nelsen's Tire because it was not named as a party until after the statute of limitations had run, and an amended complaint naming this defendant did not relate back to the date the complaint was originally filed. The plaintiff also argued that because a petition in bankruptcy was filed against Nelsen's Tire within 90 days of the time the original complaint was filed, under RCW 4.16.170 the bankruptcy stay tolled the statute of limitations. Kiehn, 45 Wn. App. at 296-97. The court rejected the argument because the 90-day period is not an extension of the statute of limitations, but instead applies where a plaintiff has tentatively commenced an action; it allows time to perfect commencement after the statute of limitations runs so long as it is within 90 days of tentative commencement. Kiehn, 45 Wn. App. at 297-98. Because no action was tentatively commenced against the defendant within the limitations period either by the original complaint or by an amended complaint that related back, RCW 4.16.170 did not apply in the case. Kiehn, 45 Wn. App. at 298. The court noted in dicta, though, that under the federal bankruptcy statute filing a complaint, as well as issuance of process, against a bankrupt violates the automatic stay provisions. Kiehn, 45 Wn. App. at 297. Therefore, the court reasoned, "if the action could have been commenced against Nelsen's tire by effecting service of process within 90 days of filing, as provided by RCW 4.16.170, the stay resulting from a bankruptcy proceeding occurring within that period would indeed have tolled the running of the statute of limitations." Id. Thus, the court appropriately recognized that if federal law had prevented service where suit had been tentatively commenced, the 90-day period of RCW 4.16.170 would have been extended and the limitations period tolled for that additional time.