The appellant appealed two assessments for director's liability under section 227.1 of the Income Tax Act regarding unremitted payroll source deductions by a corporation.
The appellant argued he was an outside director and relied on the president's assurances that remittances were current.
The Tax Court of Canada dismissed the appeal, finding the appellant did not exercise the degree of care, diligence, and skill to prevent the failure to remit that a reasonably prudent person would have exercised, as he failed to take proactive steps to verify the remittances.