Doteasy Technology Inc v. The Queen, 2009 DTC 1019, 2009 TCC 324 -- summary under Paragraph 20(1)(m)

Prepaid service fees received by an internet website hosting and domain name registration company were eligible for the s. 20(1)(m) reserve notwithstanding that in most circumstances the customers of the company were not entitled to receive a refund if they later cancelled or otherwise did not receive the services. V.A. Miller, J. applied (at para. 33) the finding in the Ellis Vision case that "the paragraph 20(1)(m) reserve was available even though the amount might be included in income under section 9 [rather than s. 12(1)(a)] so long as it was described in paragraph 12(1)(a)", and described a statement to the contrary effect in the Burrard Yarrows case as "obiter and ... incorrect".