Larocque v. MNR, 91 DTC 899 (TCC) -- summary under Subsection 227.1(4)

The issuance of a notice of reassessment was a "proceeding" for purposes of s. 227.1(4), with the result that the making of such a reassessment on the second anniversary of the date of resignation of the taxpayer as a director was permissible for purposes of s. 227.1(4). However, the taxpayer met the due diligence defence given that the failure of the operation's banker to honour the monthly remittance cheque was unexpected, and the taxpayer resigned shortly thereafter.