California Revenue & Taxation Code
Cal. Rev. & Tax. Code § 7337
“Sale” means:
(a)The transfer of title to motor vehicle fuel (other than motor vehicle fuel in a terminal) to a buyer for consideration, which may consist of money, services, or other property.
(b)The transfer of the inventory position in the motor vehicle fuel in a terminal if the buyer becomes the position holder with respect to the motor vehicle fuel.
Source: official text