If the court finds that it is inequitable to apportion interest and penalties in the manner provided in 72-16-603 because of special circumstances, it may direct apportionment thereof in the manner it finds equitable.
Equitable Power Of Court To Vary Manner Of Apportionment
Mont. Code Ann. § 72-16-604, under Apportionment of Taxes.
Mont. Code Ann. § 72-16-604