## Facts

- The IRS Intelligence Division conducted a criminal investigation into Alvin A. Beckwith, Jr.’s personal income tax liability.
- After prior investigation, two IRS special agents arranged to interview Beckwith at a private residence where he occasionally stayed.
- Agents chose an 8:00 a.m. interview time, in part to avoid interviewing Beckwith at his workplace and causing embarrassment.
- Beckwith was not formally arrested or physically restrained during the interview.
- Beckwith made statements during the interview that the government later used in a criminal tax fraud prosecution.
- Beckwith was not given Miranda warnings before or during the interview.

## Issues

1. Whether Miranda warnings are required when IRS special agents conduct a criminal tax investigation interview of a taxpayer who is not in custody.
2. Whether being the “focus” or target of a criminal investigation, without custodial restraint, triggers Miranda protections.

## Decision

- The Supreme Court affirmed the conviction (7–1; Justice Stevens did not participate).
- The Court held that Beckwith’s statements were admissible because the interview was noncustodial.
- The Court rejected the argument that investigative “focus” alone requires Miranda warnings.
- Justice Marshall concurred in the judgment, stressing careful scrutiny of voluntariness in IRS special-agent interviews.
- Justice Brennan dissented, emphasizing the coercive potential of targeted criminal tax questioning even outside a station-house setting.

## Legal Principles

- Miranda applies only to custodial interrogation: questioning initiated by law enforcement after a person is taken into custody or otherwise significantly deprived of freedom of action.
- The government’s suspicion or the fact that an investigation has centered on a person does not substitute for custody for Miranda purposes.
- The defining concern is the compulsive aspect of custodial interrogation, not the investigative stage or target status.
- The absence of warnings in a noncustodial interview does not, by itself, require suppression; it may be relevant to whether questioning was coercive under a voluntariness analysis.
- IRS special-agent interviews are assessed under the same custody standard as other law-enforcement questioning; no special Miranda rule applies solely because the inquiry is a criminal tax investigation.

## Conclusion

The Court held that a taxpayer interviewed by IRS special agents in a noncustodial setting is not entitled to Miranda warnings merely because the criminal investigation focuses on him, and statements obtained in such an interview are admissible absent custody or coercion.


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