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Lawyer disbursing client funds despite CRA Requirement to Pay liable for full amount.
The appellant, a real estate lawyer, received a Requirement to Pay (RTP) from the CRA directing her to remit funds from a client's property sale to satisfy a tax debt.
Believing the RTP only applied to a smaller lien amount which she paid, she disbursed the remaining funds to her client.
The Minister assessed the appellant under subsection 224(4) of the Income Tax Act for the full amount of the RTP ($144,675.79).
The Tax Court dismissed the appeal, holding that the appellant was liable to make the payment under the RTP and that her payment of the GST lien did not satisfy the separate Income Tax Act debt specified in the RTP.
