sought to be enforced s hall pay the tax under instant protest, or upon protest within ten days, and shall thereupon request the decision of the Collector of Internal Revenue. If the decision of the Collector of Internal Revenue is adverse, or if no decision is made by him within  six months from the date when his decision was requested, the taxpayer may proceed, at any time within two years after the payment of the tax, to bring an action against the Collector of Internal Revenue for the recovery of the sum alleged to have been il legally collected, the process to be served upon him, upon the provincial treasurer, or upon the officer collecting the tax. [2339-140.] S ECTION  1722 . Action to Contest Forfeiture of Chattel . — In case of the seizure of personal property under claim of forfeiture the owner, desiring to contest the validity of the forfeiture, may at any time before sale or destruction of the property bring a n action against the person seizing the property or having possession thereof to recover the same, and upon giving proper bond may enjoin the sale; or after the sale and within six months he may bring an action to recover the net proceeds realized at the s ale. [2339-141.] S ECTION  1723 . Form and Mode of Proceeding in Actions Arising Under Internal Revenue Law . — Civil actions and proceedings instituted in behalf of the Government under the authority of this chapter or other law enforced by the Bureau of Internal Revenue shall  be brought in the name of the Government of the Philippine Islands and shall be conducted by the provincial fiscal or the Attorney-General, or by any person designated by the latter; but no civil action for the recovery of taxes or the enforcement of any f ine, penalty, or forfeiture under any such law shall be begun without the approval of the Collector of Internal Revenue. [2339-142.] S ECTION  1724 . Authority of Collector to Make Compromises and to Refund Taxes . — The Collector of Internal Revenue may compromise any civil or other case arising under this chapter or other law relating to internal revenue, may refund taxes erroneously or i llegally received, or penalties imposed without authority, and may remit before payment any tax that appears to be unjustly assessed or excessive. He shall refund the value of internal-revenue stamps when the same are returned in good condition by the purchaser, and may in his discretion redeem or Copyright 2012 CD Technologies Asia, Inc. and Accesslaw, Inc. Philippine Law Encyclopedia 2011 517