In Ragosta v. Wilder  156 Vt. 390, 592 A.2d 367 (Vt. 1991), Wilder told Ragosta he would sell them some property for $88k, if they showed up with the money before it was sold to someone else.  Ragosta spent $7k arranging financing.  Then Wilder backed out.  The Trial Court found that Ragosta had begun performance.  The Appellate Court reversed saying that it could be retried, but only on grounds of promissory estoppel, since Ragosta was only in "preparation for performance."