PVRCo Inc is a distributor of PVRs. The corporation has 10 shareholders, including Frances and her two sons, who together hold 60 percent of the shares and are also the directors of the corporation. The sons run the business. Frances has no experience in business and is not involved in any way. She pays no attention to what is going on, although she regularly attends board meetings. In 2015, the sons started taking large amounts of money out of the business in the form of loans to themselves.

When the financial statements for 2015 were prepared, they showed that shareholder loans had ballooned from nil to $1 000 000 in a year, when revenues of the business had been only $2 000 000 over the same period. The board of directors approved the statements in June 2016. Frances was at the meeting but did not look at the statements. Within two months, the corporation was not paying its debts, and one of its creditors obtained a court order appointing a receiver to take control of the business. The receiver discovered the loans to the sons. The sons are now insolvent. Frances, however, has substantial personal assets. Is there any way that the receiver, acting on behalf of the corporation, can seek relief against Frances?