Customers of the corporation paid for services in advance, which the corporation showed as a liability on its balance sheet but deducted as a reserve in computing its income pursuant to s. 20(6). After finding that such amounts were not a reserve described in s. 181.2(3)(c), and in finding that they were includible in taxable capital pursuant to s. 181.2(3)(b) as “advances,” the Directorate stated:
The word "advance" … denotes, inter alia, the lending of money or the payment of an amount against the price of a contract for services or goods, paid before the contract is performed, the services rendered or the goods delivered.
… [I]n this context … the consideration to be received by customers is … the XXXXXXXXXX service offered by the corporation.