The Municipal Property Assessment Corporation (“MPAC”) is responsible for assessing and classifying all properties in Ontario, including the Research Park, in compliance with the Assessment Act. The Corporation of the City of Sarnia (“Sarnia”) is a municipal corporation located in the County of Lambton. The Research Park is located in Sarnia. Sarnia took no position on the application or on this appeal.
 Pursuant to s. 3(1) of the Assessment Act, all real property in Ontario is liable to assessment and taxation, subject to a list of 29 specified exemptions. Section 3(1)(9) of the Assessment Act also provides for an exemption from municipal property tax for “... land owned by a municipality, including an upper-tier municipality, a public commission or a local board as defined in the Municipal Affairs Act.”
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