Which of the following can be a limitation of a life estate?

A life estate is a form of property ownership that lasts for the duration of a person's life, known as the life tenant. Once the life tenant passes away, the ownership of the property reverts back to the original owner or passes to a pre-determined remainder beneficiary. This inherent characteristic is what makes the life estate temporary; it is directly tied to the life of the individual who holds the estate. Therefore, the correct answer highlights that the limitation of a life estate lies in its temporary nature, ending upon the death of the life tenant.

In contrast, other choices refer to different aspects of property ownership or restrictions that do not accurately describe the limitations associated with a life estate. For example, possession is not limited strictly to heirs nor is it true that a life estate cannot be sold; while transferring ownership can be complicated, a life estate may still be sold. Additionally, governmental restrictions pertain to zoning laws or land use regulations, which do not specifically relate to the nature of life estates.