The Supreme Court of Pennsylvania, applying common law rules of construction, has decided that a life tenant in personalty with the power to consume is accountable to the remainderman for the increased value of the bequeathed property.
Moltrup Estate, 424 Pa. 161, 225 A.2d 676 (1967)
David J. Pleva,
Life Estates - Power to Consume - Remainderman,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol5/iss4/10