A joint will that gives only a life interest to the survivor (rather than an absolute interest) and provides for equal distribution to the respective families of both testators upon the death of both, is a significant circumstance supporting the implication of an agreement not to revoke — distinguishing cases like [name withheld] v [name withheld] where the wills gave an absolute interest to the survivor. The making of such a joint will, combined with the family circumstances and the substance of its provisions, may provide a sufficient evidentiary basis for a finding of mutual wills without extrinsic evidence of an express agreement.
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