Lequier v. The Queen, 2010 TCC 474, 2010 DTC 1321 [at at 4219] (Informal Procedure) -- summary under Subsection 227.1(1)

The taxpayer was a corporate director with her husband. When the two separated, the taxpayer believed she had resigned as director. She did not submit a written resignation, a requirement under Alberta's Business Corporations Act. Woods J. noted that while the court will not always require a written resignation, the resignation must nevertheless be communicated to the corporation in some manner, which the taxpayer did not. She was therefore liable under s. 227.1 for the unpaid amounts.