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be repaired in dry dock. They requested that Kanter Yachts pay
for the repairs, and on July 18, 1990, Kanter Yachts' attorney
refused to undertake the repairs or to reimburse petitioners for
the repair costs. The attorney for Kanter Yachts advised
petitioners that:
With respect to the list of items referred to in
your letter, our client has carefully reviewed each
item and has determined that due to the picayune nature
of the items nothing further will be done.
In August 1990, petitioners wrote to their accountant, stating in
part:
We are also thinking of about [sic] closing the company
of Lucid Cruising since we feel at this time that in
all honesty we cannot endorse or represent the Kanter
Yacht, Inc., with the history that they have had with
us the past 3� years. * * *
On November 20, 1990, petitioners' attorney wrote to Kanter
Yachts requesting $15,000 to settle their dispute. Petitioners
did not receive a response to their proposal from the attorney
representing Kanter Yachts.
Ultimately, petitioners decided that the cost of prosecuting
a lawsuit against Kanter Yachts, a Canadian company, would be
prohibitive. The dispute between petitioners and Kanter Yachts
was never resolved.
In July 1991, petitioners dissolved their corporation.
After the dissolution, petitioners modified Trinity at a cost of
$11,000 so that they could solely manage the vessel at sea. They
explained that they did not sell Trinity because sailboat prices
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