After referring to Johnston v. MNR, [1948] SCR 486, Bowman A.C.J. stated (at p. 133):
"Rand, J. spoke of 'demolishing' the basic fact upon which the taxation rested. The term 'demolish' is somewhat infelicitous in that in connotes a wholesale annihilation of the factual underpinning of the assessment and a concomitantly high standard of proof. The standard is a civil one and requires proof on a balance of probabilities. A prima facie case suffices if it is unrebutted."