The taxpayer, which provided payroll services for a fee, received funds from its clients in advance of the required remittance of such funds by it on their behalf. The funds received:
"were not 'advances' to ADP because they were neither a payment made to ADP before it was due nor an amount to be applied against the price of the service, paid before the service is rendered, nor an amount paid to ADP for an expenditure of ADP."