Myers v. MNR, 91 DTC 72 (TCC)

The taxpayer authorized the payment of the payroll at a time when he anticipated that, notwithstanding great financial pressures, the company would be able to make the remittance on the 15th of the following month. However, in the interim, he was advised to accept the wind-up and receivership of the company, which he did. In the circumstances, he was not responsible for the company's failure to make the required remittance.

The taxpayer authorized the payment of the payroll at a time when he anticipated that, notwithstanding great financial pressures, the company would be able to make the remittance on the 15th of the following month. However, in the interim, he was advised to accept the wind-up and receivership of the company, which he did. In the circumstances, he was not responsible for the company's failure to make the required remittance.