Canadian tax authorities are proposing to troll through a list of high-volume users of the eBay Inc. online auction service.

The latest bid to snag potential tax evaders is more direct than so-called "spider" software the Canada Revenue Agency has acknowledged testing before seeking out big sellers on the Internet.

But the agency has failed thus far to get clearance to view eBay's computer records. The company's Canadian subsidiaries have requested a review of a preliminary order issued last November.

Last week, a Federal Court of Canada judge agreed with the revenue agency that eBay information on Canadian clients is not beyond its legal reach because it's held in computers outside of the country. Justice Roger Hughes did, however, agree to reconsider whether to approve a virtual fishing expedition.

The revenue agency wants information about the sales activities of everyone who supplied a Canadian address and qualified as PowerSellers by auctioning more than $1,000 worth of goods during several months in 2004 and 2005.

Lawyers for eBay Canada Ltd. and eBay CS Vancouver Inc. failed to persuade Hughes the companies do not own or possess any information about Canadian PowerSellers.

"Here eBay Canada has access to and uses information stored in a computer for the very purpose of dealing with Canadian PowerSellers," Hughes noted. "The information is not foreign, but within Canada for the purposes of section 231.2 of the Income Tax Act."

Hughes will decide later if the tax agency has "sufficient evidence to demonstrate ... a general and serious inquiry." He's awaiting the outcome of agency's pending appeal of a 2005 ruling that denied it access to member information kept by the Greater Montreal Real Estate Board.

A spokesperson said eBay expects users to comply with applicable laws, but "takes the privacy of all users very seriously. We intend to fully pursue all legal rights and remedies available to us."