MDOR cites no authority for the proposition that the involvement of a third party in a casual sale makes the sale taxable. In fact, the courts that have considered this argument have concluded the opposite-the involvement of a third party, without an express designation of law stating otherwise, is deemed not to affect the status of a casual sale.See, e.g., Sherman v. Comm'r of Rev., 24 Mass.App.Ct. 64, 67, 506 N.E.2d 160, 162 (1987) (finding third-party performance of services in aid of the property owner in making an isolated sale still is excluded from sales tax as a casual sale); State v. Tysdal, 303 Minn. 233, 237, 228 N.W.2d 230, 233 (1975) (finding agent's involvement does not alter the tax-exempt nature of the principal's transaction); Doolittle v. Johnson, 250 A.2d 822, 824 (Me.1969) (finding boat broker's involvement did not render a casual sale taxable).¶ 35. MDOR's additional argument that, because Castigliola's purchase was deemed a nontaxable retail sale in Florida, it is necessarily taxable in Mississippi, also misses the mark.

In fact, the courts that have considered this argument have concluded the opposite - the involvement of a third party, without an express designation of law stating otherwise, is deemed not to affect the status of a casual sale. See, e.g., Sherman v. Comm'r of Rev., 24 Mass. App. Ct. 64, 67, 506 N.E.2d 160, 162 (1987) (finding third-party performance of services in aid of the property owner in making an isolated sale still is excluded from sales tax as a casual sale); State v. Tysdal, 303 Minn. 233, 237, 228 N.W.2d 230, 233 (1975) (finding agent's involvement does not alter the tax-exempt nature of the principal's transaction); Doolittle v. Johnson, 250 A.2d 822, 824 (Me. 1969) (finding boat broker's involvement did not render a casual sale taxable). ¶35. MDOR's additional argument that, because Castigliola's purchase was deemed a nontaxable retail sale in Florida, it is necessarily taxable in Mississippi, also misses the mark.

Our tax statutes provide no explicit definition of the term "title," and so we look for guidance to the Uniform Commercial Code (UCC), incorporated into the General Laws as chapter 106. See Associated Testing Lab., Inc. v. Commissioner of Revenue, 429 Mass. 628, 633-634 (1999); Sherman v. Commissioner of Revenue, 24 Mass. App. Ct. 64, 66-67 (1987). See also 830 Code Mass. Regs. § 64H.6.7 (1993) (passage of title for sales tax purposes defined as in UCC).