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
Chicago Crime Commission prevalent in Chicago during the time. The businessmen who founded the crime commission did not think of themselves as a reform organization but saw crime as business work to which they applied business methods. The backlog of murder cases awaiting trial was reduced, while the public corruption and organized criminal activities of the Chicago Outfit were exposed. In 1930, the Commission first brought about the Public Enemies list, with Chicago gangster Al Capone as "Public Enemy Number One." The idea of such a list was co-opted by the FBI as the FBI's Ten Most Wanted Fugitives list. Today, the Commission's