The taxpayer, who had been assessed under s. 227(10) for his joint liability under s. 227.1 for the taxes of the corporation of which he was a director, argued that s. 227.1 only made him jointly liable for the corporation’s unpaid tax debt, and that s. 161 did not make him liable for interest on that assessment because his liability under s. 227.1 was not for “taxes payable” by him, so that such interest was required to be assessed, which was not done. Evans JA agreed (at para. 40) with this proposition, but noted that s. 227(10) provided that the Part I provisions, including s.