On August 14, 1997, Burns Boiler Co

Essay

On August 14, 1997, Burns Boiler Co. sold a boiler to Clarkson Manufacturing Co. Clarkson paid for the boiler in full, and Burns delivered to Clarkson a bill of sale. The bill of sale stated that Burns was transferring "all of its right, title, and interest" in the boiler to Clarkson. Clarkson had no immediate need for the boiler, so it remained in storage at Burns' Florida factory. On January 18, 1998, Burns delivered the boiler to Clarkson in Michigan. The state of Florida then sued Clarkson, alleging that sales tax had been due to it when title passed to Clarkson, which the state claimed was on August 14. Clarkson responded that title did not actually pass until January 18. Who is correct, and why?