October 07, 2011

Alfred D. Storrie (Appellant) v. The Minister of National Revenue (Respondent)

96 DTC 3227
Tax Court of Canada
October 10, 1995

(Court File Nos. 86-1194(IT)O, 86-1195(IT)O and 86-1196(IT)O.)

Director’s personal liability for corporation’s unremitted source deductions — Meaning of words “deduct or withhold” and “deducted or withheld” appearing in the Act not clear — Taxpayer’s personal liability under subsection?227.1(1) of I.T.A. accordingly limited to (penalty) 10% of the amount that should have been deducted or withheld under subsection?227(8) I.T.A. — I.T.A. ss.?153(1), 227(4), 227(5), 227(8), 227(9), 227(13) and 227.1(1).