The incorrect statement about a fee simple absolute estate is that it terminates upon the holder's death; in reality, it typically passes to heirs. A fee simple absolute allows maximum control and ownership of a property, and the holder can transfer rights freely. Thus, option D is the choice that is not true regarding this type of estate.
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A fee simple absolute estate does grant maximum control, reflects the largest estate in land, and allows for the transfer of rights. However, it does not terminate upon death, as it is typically inherited. Therefore, option D is the incorrect statement regarding fee simple absolute estates. ;