The Department shall, through the competent body, sell properties seized in accordance with the provisions of seizure.

The expenses of the seizure and sale shall be paid first from the sales returns, then the tax and fines. Any remaining amount shall be returned to the taxpayer.

Sale of the taxpayer's properties shall be suspended during the period of the administrative or judicial review of the assessment on the basis of which the seizure was made, except for:

1. perishable properties; and

2. properties sold by the Department upon the taxpayer's request.