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 Johns Hopkins Hospital in Baltimore for the treatment of paresis (caused by late-stage syphilis). Hopkins refused to admit him based solely on his reputation, but Union Memorial Hospital accepted him. Capone was grateful for the compassionate care that he received and donated two Japanese weeping cherry trees to Union Memorial Hospital in 1939. A very sickly Capone left Baltimore on March 20, 1940, after a few weeks inpatient and a few weeks outpatient, for Palm Island, Florida. In 1946, his physician and a Baltimore psychiatrist performed examinations and concluded that Capone had the mentality of a 12-year-old child. Capone spent