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
Al Capone Torrio was returning from a shopping trip when he was shot several times. After recovering, he effectively resigned and handed control to Capone, age 26, who became the new boss of an organization that took in illegal breweries and a transportation network that reached to Canada, with political and law-enforcement protection. In turn, he was able to use more violence to increase revenue. An establishment that refused to purchase liquor from him often got blown up, and as many as 100 people were killed in such bombings during the 1920s. Rivals saw Capone as responsible for the proliferation of brothels