The Florida District Court of Appeal recently upheld a ruling in a tax dispute involving Circle Citgo, Inc. and the Department of Revenue. The decision, made on October 14, 2026, affects how businesses in Florida handle tax obligations and compliance with state regulations.

Circle Citgo, Inc., a gas station and convenience store operator, challenged a ruling from the Department of Revenue regarding its tax liabilities. The outcome of this case is significant for businesses in Florida, as it clarifies the legal landscape surrounding tax disputes and compliance.

The case, Circle Citgo, Inc. v. Department of Revenue, was filed under docket number 1D2025-3187. The court's decision could set a precedent for similar cases in the future, impacting how businesses navigate their tax responsibilities.

Background

Circle Citgo, Inc. is a gas station and convenience store located in Florida. The company found itself in a dispute with the Florida Department of Revenue over its tax obligations. The specifics of the tax liabilities in question were not detailed in the court filing.

The dispute arose when the Department of Revenue assessed taxes that Circle Citgo believed were incorrect. The company argued that the assessment was unjust and sought to challenge the ruling in court. The case was brought before the District Court of Appeal after lower court decisions did not favor Circle Citgo.

The appeal was represented by Jonathan W. Taylor, Joseph C. Moffa, and Jeanette E. Moffa from the law firm Moffa, Sutton, & Donnini, P.A., based in Fort Lauderdale. On the other side, the Department of Revenue was represented by Jacek P. Stramski, Special Counsel, along with Attorney General James Uthmeier and Senior Assistant Attorney General Kiran B. Joshi.

The Ruling

The District Court of Appeal ruled in favor of the Department of Revenue, affirming the previous decisions made by lower courts. The court's opinion was brief and stated simply, “AFFIRMED,” indicating that the court found no merit in Circle Citgo's arguments against the tax assessment.

Judges Lewis, Kelsey, and Treadwell concurred with the ruling, providing a unanimous decision. The court's affirmation means that the tax liabilities assessed by the Department of Revenue will stand, and Circle Citgo must comply with the ruling.

The court filing did not provide extensive details on the reasoning behind the decision, but the affirmation suggests that the court found the Department of Revenue's assessment to be valid and lawful.

Impact

This ruling has significant implications for businesses operating in Florida. It reinforces the authority of the Department of Revenue to assess taxes and indicates that businesses may face challenges if they dispute such assessments without strong evidence.

The decision may also set a precedent for future tax disputes between businesses and the Department of Revenue, potentially leading to stricter compliance requirements for companies in similar situations. Businesses may need to reevaluate their tax strategies and ensure they are fully compliant with state tax laws to avoid similar disputes.

What's Next

Details were not available in the court filing regarding whether Circle Citgo plans to appeal the ruling. However, the case is not final until any timely motions under Florida Rules of Appellate Procedure are resolved. It remains to be seen if there will be any related cases pending that could further clarify tax obligations for businesses in Florida.