all the claims, for this purpose.” (footnotes omitted)). Where neither the debtor nor the creditor directs how the debtor’s payment should be applied, the common law rule also allows the payment to be apportioned among the debts in order to prevent the statute of limitations from running on any of those debts. See 60 Am. Jur. 2d Payment § 71 (2014) (“[W]ithout specific application by either the debtor or the creditor, the law will apply payments ratably to prevent any of several notes from being barred by the statute of limitations.”). The requirement for a debtor to identify the particular debt that a partial payment applies to will become a material factor when the statute of limitations on that particular debt has already run. See Drake v. Tyner, 914 P.2d 519, 523 (Colo. App. 1996) (<HOLDING>); accord Neal v. Gideon, 138 P.2d 419, 420
holding that a creditor did not incur debt for the purpose of set off where it stopped payment to the debtor holding where a debtor does not exercise hisher right to designate which one of several debts to which a payment should be applied creditor may apply payment as he she chooses even if there is a surety or guarantor liable on one of the debts holding that the statute of limitations does not run on a debtorinpossession holding that a payment is under the plan when the debt is provided for in the plan holding that when a creditor on multiple debts applies an undesignated partial payment by the debtor to a debt on which the statute of limitations has not yet run the payment tolls the statute of limitations on that debt