Allocation of tax, penalty, and interest in case of payments made pursuant to offers accepted in compromise of taxes will be made as specified in the agreement. If no allocation is specified in the offer or agreement, or if no agreement has been accepted and the amount of the offer exceeds combined tax and penalties, payments received (whether installment or lump sum) will be applied to tax, penalty, and interest in that order, beginning with the earliest period.
N.J. Admin. Code § 18:33-2.10