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 and the Bowery Boys. He then joined the Brooklyn Rippers, and then the powerful Five Points Gang based in Lower Manhattan. During this time, he was employed and mentored by fellow racketeer Frankie Yale, a bartender in a Coney Island dance hall and saloon called the Harvard Inn. Capone inadvertently insulted a woman while working the door at a Brooklyn night club and was slashed by her brother Frank Gallucio. The wounds led to the nickname "Scarface" which Capone loathed. When he was photographed, he hid the scarred left side of his face, saying that the injuries were war wounds.