In Zvilna v R, 2022 TCC 50 (informal procedure), the Court accepted the taxpayer’s oral testimony that he had resigned from a corporation in writing even though the document in question was never entered into evidence. The taxpayer and his wife had separated. The taxpayer stated that he had “left the corporation” to his wife by, among other things, leaving a written resignation with her. It probably helped that the taxpayer had stated his intention to resign in a written separation agreement that was before the Court.
Marc Pelletier “Directors’ Liability: Taxpayer Held to Have Resigned as Director Despite Lack of Paperwork” 12:4 Canadian Tax Focus (November 2022)
