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
Pre-Code crime films be rejected by local censors. Justus D. Barnes, was "Bronco Billy Anderson", leader of an outlaw gang, from the silent film, "The Great Train Robbery" (1903), the first, "Western", ever filmed. The Western was a subgenre, of crime films. Scenes where criminals aimed guns at the camera, were considered inappropriate by many state censor boards, in the pre-Code and Code era, and were removed from public viewing. In the early 1930s, several real life criminals became celebrities. Two in particular captured the American imagination: Al Capone and John Dillinger. Gangsters like Capone had transformed the perception of entire towns. Capone