Lloyd Patterson - Page 6

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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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