After a trial in this adversary proceeding, the court applied a two-step analysis to determine the validity of a landowner's claim under an oral lease agreement and that a portion of the debt should be excepted from discharge under § 523(a)(2)(A). The court found that the debtor made false representations to the landowner regarding his plans to pay the landowner's portion of the crop proceeds. The evidence did not support a finding of actual fraud by the debtor, however, because he "did not engage in deception, trickery or a scheme to deprive" the landowner of the proceeds.