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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 the
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