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Beckwith v. United States, 425 U.S. 341 (1976).

Filing tax returns at one time or another becomes a part of every working American's life. In the large majority of cases, the returns are filed honestly and, if ever audited, receive the approval of the Internal Revenue Service (IRS). But what if this approval is not forthcoming? Indeed, what if the audit results in a finding of criminal liability? The fifth and sixth amendments guarantee freedom from self-incrimination, and the right to have assistance of counsel in all criminal prosecutions. Miranda v. Arizona, a controversial decision which affects many of the contacts between police, government investigative agencies, and the people being investigated by them, specifically stated these rights among others. In Beckwith v. United States, the Supreme Court was asked to decide "whether a special agent of the Internal Revenue Service, investigating potential criminal income tax violations, must, in an interview with a taxpayer, not in custody, give the warnings called for by this Court's decision in Miranda v. Arizona. After affirming the district court's holding that the statements made by Beckwith were admissible against him in the ensuing tax fraud prosecution even though he had not been given the full Miranda warnings prior to the interview, the Court held that it was the "custodial nature" of an interrogation which triggered the necessity for adherence to the specific requirements of its Miranda holding. Speaking for the majority in Beckwith, Chief Justice Burger stated that previous Supreme Court decisions specifically stressed the custodial factor and confined their rulings to situations where this factor was present. Since Beckwith was at no time taken into custody during the investigation, his claim that he was entitled to the Miranda warnings was found to be without merit.

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