The Supreme Court of Pennsylvania has held that a devise giving a life estate and a general testamentary power of appointment is not equivalent to a fee simple when there is included in the devise a gift over in default of appointment.
Estate of Curtis, 452 Pa. 527, 307 A.2d 251 (1973).
Mark M. Levine,
Estates and Trusts - Future Interests - Power of Appointment,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol12/iss4/11