Burton v. The Queen, 2006 DTC 2001, 2005 TCC 762 (Informal Procedure) -- summary under Subsection 227.1(3)

MacArthur J. accepted testimony that the taxpayer had resigned as director early in 2002 notwithstanding that the only copy of the written notice of resignation was mislaid and not found until the taxpayer was assessed under s. 227.1, and that notice was not filed in the minute book or communicated to the Ontario Corporations branch. Accordingly, the Minister was barred from assessing the taxpayer under s. 227.1 more than two years after the resignation in respect of remittance obligations arising after the resignation.