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 was a friend of Capone's, and he was kidnapped and killed by Moran and Drucci in January 1927. Capone became increasingly security-minded and desirous of getting away from Chicago. As a precaution, he and his entourage would often show up suddenly at one of Chicago's train depots and buy up an entire Pullman sleeper car on a night train to Cleveland, Omaha, Kansas City, Little Rock, or Hot Springs, where they would spend a week in luxury hotel suites under assumed names. In 1928, Capone paid $40,000 to beer magnate August Busch for a 14-room retreat at 93 Palm Avenue