Is Mediacom a tenant or lessee of a city-owned bus shelter that is exempt from a tax exemption?

Taxation is the rule and exemption is the exception. The onus of showing that property is within an exemption is on he who claims it: see Toronto Transit Com'n v. City of Toronto, 1971 CanLII 8 (SCC), [1971] S.C.R. 746 at pp. 752-3, 18 D.L.R. (3d) 68 at p. 73 (S.C.C.). It is important to bear this in mind as the foundation of the applicant's position with respect to each exemption is not the same. Under s. 3, para. 8 it is submitted that Mediacom does not occupy the shelters as tenant or lessee while under s. 3, para. 9 it is submitted in addition that the shelters belong to the city.