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petitioner's accounts receivables and inventory. Lykes Agri
Sales never foreclosed on petitioner.
Petitioner did not own any farm land.
C. Ward's Relationship With Petitioner's Customers
1. Ward's Expertise
Ward spent much of his time with farmers in the Hastings
area. Petitioner's customers valued Ward's expertise and greatly
respected him. They sought and relied on his advice. They
sometimes called him at night at his home to ask for help. He
was knowledgeable, helpful, and concerned about their problems.
Ward visited his customers' farms daily, inspected their soil and
crops, took leaf and soil samples, and advised them about
fertilizers, herbicides, and pesticides. He showed his customers
how to apply the chemicals. Ward charged for testing soil
samples but he did not charge for advice.
2. Ward's and Petitioner's Financial Assistance to Farmers
Ward often gave financial assistance to farmers. Many farms
in the Hastings area were heavily mortgaged during the years at
issue. Harvest and market conditions in the Hastings area
fluctuated greatly during the years in issue. Ward sometimes
cosigned notes for farmers and lent them money. He often gave
farmers credit because they could not pay for merchandise.
Ward borrowed money from a bank to pay for the merchandise
that he ordered for the farmers. He deposited the borrowed money
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