Lamarre Proulx found (at p. 2243) that even if evidence, that a portion of the remuneration paid to employees of the taxpayer represented fraudulent overpayments attributable to overstatements of overtime, were accepted, this did not provide an excuse for the taxpayer to fail to remit amounts which it had shown as being deducted in respect of such alleged overpayment:
"Once the deduction has been made, it has to be withheld. It is trust money, it then has to be remitted to the Receiver General."