In Estate of Nunn (1974) 10 Cal.3d 799, the will gave the surviving life tenant "the power to invade the corpus for the life tenant's 'use and need' as the life tenant 'may determine.'" ( Id. at p. 803.) The court stated: "The principal difficulties are associated with the word 'need.' . . . para. . . . The concept of need or needs is a fluid one with a meaning which varies with and is to be derived from context . . . . para. There is no rational basis in the instant case to define 'need' in terms of a dollar amount or in terms of an existing or identifiable standard of living. Without excluding the possibility that some proposed or actual invasion might be deemed so inappropriate as to be impermissible, we would in general interpret the power granted as permitting virtually any invasion for any personal expense or standard of living adopted by the surviving life tenant. Such conclusion is bolstered by language describing the need to be 'as she may determine.' . . ." ( Id. at p. 807.)