Unremitted payroll deductions

A corporation went out of business in 2006.  In 2013, the taxpayer, a director, was assessed for unremitted payroll deductions of the corporation.  He appealed.  The Tax Court of Canada threw out the appeal as he had never resigned as a director.  Also, he had never done any due diligence.  That is, he couldn’t prove he had taken steps to learn of the remittances, taken steps to verify they had been paid, or taken steps to satisfy discrepancies.  These are all steps required of a reasonable prudent director to establish a defence of due diligence.  The kicker … he also had to pay court costs to the government.