The most significant development in 1969 in the area of trusts and estates was the codification of the law regarding powers of appointment. Other legislation subjects irrevocable inter vivos trusts to the jurisdiction of the Superior Court. In the area of judicial developments, there were two cases of first impression. Estate of Pernas, dealt with the allocation as to principal or income of gains distributed from mutual funds. The other, Estate of Phillips, concerned the admission to probate of a will executed by a Californian who had been adjudicated an incompetent in Illinois prior to his coming to California.