The Seminole Tribe of Florida has filed an appeal with the Florida Supreme Court regarding the Fourth District Court of Appeals’ decision in Florida Dep’t of Revenue v. Seminole Tribe of Florida, 65 So. 2d 1094 (Fla. 4th DCA 2011). The issue at the heart of the controversy is whether Florida may lawfully impose motor fuel taxes on the Tribe’s purchases of fuel when such purchases are made off the reservation and tribal lands, but are used for the performance of the Tribe’s functions as a sovereign government. The Fourth District Court of Appeals concluded that such off-reservation purchases were taxable even though the legal incidence of the tax was on the Tribe.