Van Leenen v. MNR, 91 DTC 1265, [1991] 2 CTC 2442 (TCC) -- summary under Subsection 227.1(3)

The taxpayer, who was the president and majority shareholder of the corporation, was found to have been deficient in relying on established administrative procedures for the remittance of source deductions when he knew the corporation was under tremendous financial pressures and "could pay only those creditors who shouted the loudest" (p. 1268). In addition, the taxpayer was unable to establish that he should be relieved of liability on the basis that the Crown should have been more vigilant in collecting the amounts in question from the assets of the corporation.