Matthew Mellon died in April 2018. He was fifty-four. He was an heir of the Mellon banking family, an early investor in cryptocurrency, and at the time of his death the largest individual holder of XRP outside Ripple itself. His total estate was valued at approximately $197 million.^[1] Of that, more than $193 million sat in XRP alone. By the estate counsel's own filing, ninety-seven percent of the estate's value was held in a single asset class.^[1] Those holdings were spread across wallets he had personally engineered to be unreachable by anyone else.

The decisions that produced this outcome were not careless. They were the product of a security philosophy taken to its terminal point. Mellon had reportedly come to believe that the size of his holding made him a target. He responded by distributing his keys across multiple cold wallets, registering the wallets under names other than his own, and storing the access materials in safe deposit boxes in cities scattered across the United States. Nobody, by his own design, knew the full picture.

His will, written before the cryptocurrency holding existed in any meaningful size, did not mention XRP. It did not name the wallets. It did not name the safe deposit boxes. It described an estate that, on paper, no longer reflected what he actually owned.

The recovery

Mellon's lawyers were eventually able to reach the holdings only because Ripple, as the issuer of XRP, agreed to assist. This is the part of the story most worth pausing on. A cryptocurrency lawyer cited in the Daily Dot's reporting at the time observed that the family should consider themselves fortunate, because that kind of cooperation from an issuer is rare.^[1] For ordinary holders, there is no equivalent point of contact. The asset is the asset, the keys are the keys, and the estate is on its own.

Even with Ripple's assistance, a separate problem began to compound. Mellon had previously signed an agreement with Ripple capping the rate at which his XRP could be sold into the market. The IRS's own answer in the estate tax case describes this as a "purported Settlement and Release Agreement" containing what counsel called "Liquidation Restrictions".^[2] That agreement, sensible while he was alive, became a serious constraint after death. The estate had tax obligations and creditors. It needed cash. It could only liquidate slowly.

One might think that an estate comprised ninety-seven percent by a single asset would be a straightforward matter to administer.

That sentence appears, in much the same form, in court documents filed by the estate's lawyers.^[1] It captures the shape of the problem more cleanly than any commentary.

The cost of delay

Between Mellon's death in April 2018 and the partial settlement of the estate by the end of 2019, the price of XRP fell sharply. Court records cited in the Daily Dot's reporting describe the estate's value, by the close of 2019, as less than half what it had been at the start of administration.^[1] A valuation analysis from the firm Empire, filed later in the estate's tax case, concluded that liquidating the remaining XRP at the rate the agreement allowed would take approximately 3.91 years.^[2] The estate paid sixty million dollars in federal estate tax in late 2020 and still left a substantial portion of that liability outstanding.^[1] A holding that had once been valued, at peak, at close to a billion dollars was reduced, by the time it was distributed, to a fraction of its administered value.

The estate finally closed in January 2021, almost three years after Mellon died.^[3]