Bourget v. The Queen, 2011 DTC 1032 [at at 143], 2010 TCC 642 (Informal Procedure) -- summary under Income-Producing Purpose

The taxpayer could not deduct a payment made to the Receiver General in satisfaction of his director's liability for source deductions under s. 227.1. Sheridan J. stated at para. 5: "By the time the Appellant made the payment to the Receiver General in respect of [his corporation's] source deductions, the company had long since ceased operations; from this it follows that there was no possibility of the Appellant having acquired his debt for the purposes [of producing income from business]."