Moll v. The Queen, 2008 DTC 3420, 2008 TCC 234 (Informal Procedure) -- summary under Subsection 227.1(4)

A written resignation of the taxpayer as sole director of the corporation dated more than two years before his assessment under s. 227.1 was found to have been fabricated after the fact. However, even if he had resigned on the date of the purported letter, he would have continued to be a director under s. 115(4) of the Business Corporations Act (Ontario) (which stipulates that "any person who manages or supervises the management of the business and affairs of the corporation shall be deemed to be a director" following that person's resignation), given that after the date of the purported resignation he continued to hold himself out as the director of the corporation and continued to do various acts such as meeting with CRA and giving them post-dated cheques.