A transfer of delivery trucks at the time of a merger was nor subject to Pennsylvania sales and use tax. The transfer did not involve any consideration, which is a requirement in the definition of a sale at retail. Therefore, the Court ruled that the trucks were transferred by operation of law, as defined in the law governing corporate mergers, and not a transaction where a consideration was agreed upon. (Legal Letter Ruling No. SUT-04-017, Pennsylvania Department of Revenue, may 17, 2004 (reissued May 18, 2009)