In re Estate of Bozarth, No. 4-13-0309, 2014 Ill. App. LEXIS 39 (Ill. Ct. App. Jan. 30, 2014)

(decedent bequeathed his personal property to his wife, the stepmother of his son, “to be hers to use and enjoy for and during the term of her natural lifetime”; the will provided that at the death of the wife, “all that remains of my estate” was to be divided amongst his son’s children; the wife survived the decedent by 16 years; after the wife's death, the grandchildren sought to recover the value of a $100,800.79 bank account that existed at the time of the death of the decedent; the wife's argued that she was entitled to consume the personal property during her lifetime, and the trial court agreed; in reversing that portion of the order, the court found that in Illinois, a life estate in personal property did not grant the life tenant the right to consume the corpus of the property; rather, the wife was entitled only to receive income from the principal; to grant to a life tenant the right to invade and consume the principal, a testator had to grant such a right in explicit language).