RULE IN. "When the ancestor, by any gift or conveyance, tak-eth an estate of freehold, and in the same gift or conveyance an estate is limited, either mediately or immediately, to his heirs in fee or in tail, the ‘heirs’ are words of limitation of the estate, and not words of pur-chase.” 1 Coke, 104
Source: Black's Law Dictionary 2nd Ed (1910)