- 6 - contributions. Yet, he never put any such document in evidence. Petitioner testified that: "I get invited to various churches to hear the preacher or the speaker so I go there, I put money in the collection plate * * *. It could be a $50 bill. It could be $25 or $30." We are not required to accept petitioner's self- serving statements as gospel. Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). Nevertheless, we believe petitioner went to churches and made contributions to those churches. Where the Court is satisfied that the taxpayer is entitled to some deduction but where the records are inadequate to establish the amount of the deduction, the Court may make an approximation of the amount of the deduction. Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930). In such cases we are cautioned to bear heavily against the taxpayer "whose inexactitude is of his own making." Cohan v. Commissioner, supra at 544. We find that petitioner is entitled to deduct $120 as a charitable contribution. Respondent has conceded that petitioner made a $2,000 contribution to an Individual Retirement Account (IRA). Respondent contends that this IRA contribution is subject to the limitation set forth in section 219(g)(3). In general, a taxpayer is entitled to deduct the amount he contributes to an IRA, although the deduction allowable for any taxable year may not exceed the lesser of an amount equal to thePage: Previous 1 2 3 4 5 6 7 8 9 Next
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