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
Frank Capone than Al Capone. In fact, the third gunman was later positively identified as one David Hedlin; the police had wounded him, as well. At the end of the day, the Capone candidate Klenha had won. After Frank's death, the Chicago newspapers were full of articles either praising or condemning the CPD. A coroner's inquest later determined that Frank's killing was a justifiable shooting since Frank had been resisting arrest. On April 4, 1924, Frank Capone received an extravagant funeral, with $20,000 worth of flowers placed around the silver-plated casket and over 150 cars in the motorcade. Al purchased the flowers