The Minister assessed the appellant corporation under subsection 224(4) of the Income Tax Act for failing to comply with a requirement to pay issued in respect of a tax debtor who was the corporation's sole shareholder and director.
The tax debtor had withdrawn cash from the corporation's bank account to pay his spouse's credit card bills while the requirement was in effect.
The Tax Court of Canada dismissed the appeal, finding that the corporation had a responsibility at law to make payments to the tax debtor from available funds, and the withdrawn sums should have been remitted to the Receiver General.
