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
Louis Capone pastries) in Brooklyn. The "pasticceria" became a popular hangout for teenagers, including future street gang leaders Abe Reles and Harry Maione. Capone built up a rapport with the boys by giving them free food. These young men soon became Capone's protégés in crime. Capone had strong connections with the Purple Gang of Detroit, and was operating loansharking operations in both Detroit and New York. He was also involved in labor racketeering with the local Plasterers Union and had close ties with mobster Joe Adonis. With the end of the Castellammarese War in 1931, Reles' and Maione's gangs developed into a