§ 7473. Allocation of payments (a) Any payment received by the Commissioner from any taxpayer with respect to a tax liability of the taxpayer may be applied to any tax liability in the following order of priority, notwithstanding any direction by the taxpayer to the contrary: (1) first, against any portion of any tax liability initially incurred with respect to a preceding taxable year, with the portion incurred with respect to the earliest preceding taxable year to be satisfied before any portion incurred with respect to any succeeding taxable year; and (2) next, against any portion of any tax liability incurred with respect to the current taxable year. (b) As to each portion, the payment shall be applied as follows: (1) first, to the amount of any interest; (2) next, to the amount of any penalty; (3) next, to the amount of any fee; and (4) next, to the amount of any unpaid tax, incurred with respect to the taxable year.
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