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Mr. Farnsworth did, 20 or more years of service as a district
manager.
Moreover, unlike the taxpayers in Jackson, Gump, and
Milligan, the payments to which Mr. Farnsworth was entitled were
not subject to reduction for events unrelated to his services and
occurring after termination.
There is also evidence in the record to suggest a
significant relationship between Mr. Farnsworth’s rights under
the DMAA to recover “contract value” at termination and his
agreement at inception of the DMAA to have the retention amounts
withheld. Mr. Diltz testified that the retention amounts were
imposed in order to enable Farmers to recover from a successor
manager the cost of paying “contract value” to the retiring
manager replaced by the successor. Prior to the requirement for
the successor manager to have retention amounts withheld, there
was no provision for the payment of contract value upon
termination. While there is no relationship between the new
manager’s retention amount and the “contract value” amount
(because the retention amount is based on the former manager’s
contract value), the successor manager’s right to contract value
upon his retirement was conditioned upon his agreement to have
the retention amounts withheld. There was thus a causal
relationship between the right to contract value and the
retention requirement. The causal relationship between Mr.
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