Section 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.Amended by 2022 , No. 105, § 560, eff. 7/1/2022.Added 1969, No. 269 (Adj. Sess.), § 1, eff. date, see note under § 7401 of this title.