... refund to Taxpayer. In following this procedure Director relies on N.J.S.A . 54:49-17 which provides: Whenever any taxpayer shall be entitled to any ... Total due from Taxpayer $770,084 $2,105,131 I N.J.S.A . 54:49-17 permits Director to apply overpayments to amounts due to the ... the refund claim was an issue and are therefore inapposite. N.J.S.A . 54:49-17 does permit an offset and in this case, Director did ... which it was entitled. Director concedes that its authority under N.J.S.A . 54:49-17 is discretionary. Equitable principles and discretionary authority should be compatible ...