Al Capone Mabel Walker Willebrandt recognized that mob figures publicly led lavish lifestyles yet never filed tax returns, and thus could be convicted of tax evasion without requiring hard evidence to get testimony about their other crimes. She tested this approach by prosecuting a South Carolina bootlegger. In 1927, the Supreme Court ruled in "United States v. Sullivan" that illegally earned income was subject to income tax; Justice Oliver Wendell Holmes Jr. rejected the argument that the Fifth Amendment protected criminals from reporting illegal income. The IRS special investigation unit chose Frank J. Wilson to investigate Capone, with the focus on his
Capone-N-Noreaga several tracks was released in 2004, entitled "What Up 2 Da Hood Thugged Out", Later that year, the duo found itself implicated in a non-fatal shooting between rival hip-hop groups, one of which included fellow Brooklyn-based rapper Lil' Kim, after a chance encounter outside New York radio station Hot 97. Capone-n-Noreaga have denied any involvement in the shooting, for which the group was not charged. In early 2005, Def Jam released Capone from his contract while retaining N.O.R.E.; Capone released his solo debut album "Pain, Time, and Glory", later the same year. In 2006, N.O.R.E. brought up the possibility of