Billionaire Harlan Crow bought property from Justice Clarence Thomas — two vacant lots and the house where Thomas’ mother was living — which was not disclosed, ProPublica reports.
“The purchase put Crow in an unusual position: He now owned the house where the justice’s elderly mother was living. Soon after the sale was completed, contractors began work on tens of thousands of dollars of improvements on the two-bedroom, one-bathroom home, which looks out onto a patch of orange trees. The renovations included a carport, a repaired roof and a new fence and gates, according to city permit records and blueprints.”
The only reason to not include this in your financial disclosures is if you want to hide it.