Westcoast Petroleum Ltd. v. The Queen, 89 DTC 5153, [1989] 1 CTC 363 (FCTD) -- summary under Paragraph 18(1)(e)

Northern Central Gas was followed. Teitelbaum J. noted (p. 5167) that although "where amounts are put into reserve accounts to cover liabilities which are legally binding and ascertainable on the taxation year but which may not be enforced until a later date, such amounts in certain circumstances may be deducted from income", here there was no legally binding obligation on the taxpayer to refund the amounts in question to third parties at the end of the taxation year.