A testamentary gift of property 'for as long as [the beneficiary] needs it' is void for uncertainty because 'need' provides no ascertainable criteria for determining the duration of the gift. The word 'need' is not synonymous with 'want' and falls between 'want' and 'cannot survive without'. Where a gift by way of limitation is uncertain as to its duration, the entire gift fails. The prima facie rule that words of futurity in a will speak from the date of the will may be displaced where the language of the clause refers to the date of death and contextual evidence supports that construction.
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