In the matter before us, notices of deficiency were mailed on November 3 and December 8, 1983. ⁹ Petitioner filed a petition (docket No. 2690-84) from a copy of a statutory notice for 1978 mailed to its representatives on November 3. 1985 U.S. Tax Ct. LEXIS 117">*127 ¹⁰ Petitioner also filed a petition (this action) based on the notice of deficiency for the taxable years ended June 30, 1978, 1979, 1980, and 1981, mailed to it on December1985 U.S. Tax Ct. LEXIS 117">*126 8, 1983. Where a taxpayer files a petition from a notice of deficiency, respondent has no authority to send the taxpayer a second notice for the same taxable year and tax liability. Barth Foundation v. Commissioner, 77 T.C. 1008">77 T.C. 1008, 77 T.C. 1008">1013 (1981); McCue v. Commissioner, 1 T.C. 986">1 T.C. 986 (1943). Accordingly, the notice of deficiency in this action, which was a second notice as to the taxable year ended June 30, 1978, is invalid for that year. A valid petition is the basis of the Tax Court's jurisdiction. To be valid, a petition must be filed from a valid statutory notice. See Midland Mortgage Co. v. Commissioner, 73 T.C. 902">73 T.C. 902, 73 T.C. 902">907 (1980); 1 T.C. 986">McCue v. Commissioner, supra at 988. The Court therefore has no jurisdiction as to the taxable year ended June 30, 1978, from the petition filed in this action since the petition is invalid as to that year.

In order to decide whether the statutory notice of deficiency in this action is nevertheless valid as to the taxable years ended June 30, 1979, 1980, and 1981, we must consider the function of the notice. A statutory notice of deficiency is a jurisdictional prerequisite to a taxpayer's suit seeking the Tax Court's redetermination of respondent's determination of the tax liability. Laing v. United States, 423 U.S. 161">423 U.S. 161, 423 U.S. 161">165 n. 4 (1976). No particular form is required for a statutory notice of deficiency. Scar v. Commissioner, 81 T.C. 855">81 T.C. 855, 81 T.C. 855">860 (1983); Foster v. Commissioner, 80 T.C. 34">80 T.C. 34, 80 T.C. 34">229 (1983),1985 U.S. Tax Ct. LEXIS 117">*128 on appeal (9th Cir., Sept. 30, 1983); Jarvis v. Commissioner, 78 T.C. 646">78 T.C. 646, 78 T.C. 646">65584 T.C. 248">*253 (1982). All that is required is that the notice provide formal notification that a deficiency in tax has been determined. ¹¹Foster v. Commissioner, supra at 229. "[The] notice is only to advise the person who is to pay the deficiency that the Commissioner means to assess him; anything that does this unequivocally is good enough." Olsen v. Helvering, 88 F.2d 650">88 F.2d 650, 88 F.2d 650">651 (2d Cir. 1937).

1985 U.S. Tax Ct. LEXIS 117">*129 Petitioner asserts, "where a court's jurisdiction over a matter is strictly statutory, ¹² there must be complete and exact compliance with the statutory requirements before jurisdiction is perfected." Petitioner cites numerous cases, none of which concern Federal taxation, for the proposition that a notice of deficiency that spans several tax years must be valid for each year in order for this Court to have jurisdiction over any of the years. Statutory and case law on Federal taxation, however, simply do not support petitioner's position.

As our decision in Baron v. Commissioner, 71 T.C. 1028">71 T.C. 1028 (1979), illustrates, a statutory notice is not wholly invalid where the petition filed from it is invalid in part for lack of jurisdiction. In 71 T.C. 1028">Baron v. Commissioner, supra, a notice of deficiency was jointly issued to a husband and wife, who petitioned1985 U.S. Tax Ct. LEXIS 117">*130 the Tax Court for redetermination of their tax liability. The statutory notice was sent after the husband had been adjudicated a bankrupt. The taxpayers argued that under section 6871(b), ¹³ the Tax Court lacked jurisdiction as to 84 T.C. 248">*254 the husband and therefore the statutory notice was null as to him; and that, because the notice had been issued jointly, it was null as to the wife as well. Although we agreed with the taxpayers that the Tax Court had no jurisdiction over the husband, we nevertheless found the statutory notice valid with respect to the wife and held that the Tax Court had jurisdiction as to her, since she was a separate taxpayer and section 6871(b) did not prohibit her from filing a petition with the Court.

1985 U.S. Tax Ct. LEXIS 117">*131 The jurisdiction of the Tax Court over separate taxable years, rather than as to separate taxpayers, is at issue in this case. Taxes are levied annually, and each taxable year may be the basis of a separate cause of action. Commissioner v. Sunnen, 333 U.S. 591">333 U.S. 591, 333 U.S. 591">598 (1948). Where the Commissioner determines a deficiency as to several taxable years, the taxpayer may petition the Tax Court to redetermine the deficiency as to any or all of the years. John R. Thompson Co. v. Commissioner, 10 B.T.A. 57">10 B.T.A. 57, 10 B.T.A. 57">61 (1928). For example, where the Commissioner in a statutory notice determines a deficiency as to two separate taxable years, the taxpayer may file a petition with respect to one or both years (or may file no petition and pay the determined deficiencies). Likewise, a taxpayer may file one petition contesting deficiencies determined for multiple years in separate notices. Egan v. Commissioner, 41 B.T.A. 204">41 B.T.A. 204 (1940). In 71 T.C. 1028">Baron v. Commissioner, supra, we held that a statutory notice sent jointly to separate taxpayers was valid as to one taxpayer, even though the Tax1985 U.S. Tax Ct. LEXIS 117">*132 Court lacked jurisdiction as to the other taxpayer. Similarly, we regard a notice as to several separate taxable years as divisible: the notice may be valid with respect to certain taxable years even though, with respect to other years, the notice is invalid and the Tax Court consequently lacks jurisdiction. Cf. S-K Liquidating Co. v. Commissioner, 64 T.C. 713">64 T.C. 713 (1975).

In the matter before us, had respondent on December 8, 1983, sent petitioner separate notices of deficiency for the taxable years ended June 30, 1978, 1979, 1980, and 1981, and had petitioner timely filed separate petitions for each of those years, the Court would have had jurisdiction as to the taxable years ended June 30, 1979, 1980, and 1981. We know of no reason to reach a different result because respondent used one 84 T.C. 248">*255 notice determining deficiencies in each of 4 separate taxable years, from which a single petition was filed.

The statutory notice in this action advised petitioner that the Commissioner had determined deficiencies in petitioner's taxable years ended June 30, 1979, 1980, and 1981, in amounts that the notice set forth. ¹⁴ That was all that was necessary for1985 U.S. Tax Ct. LEXIS 117">*133 the notice to be valid for those years. See 81 T.C. 855">Scar v. Commissioner, supra at 860-861; 41 B.T.A. 204">Foster v. Commissioner, supra at 229-230. We hold that the petition filed from the instant notice gave this Court jurisdiction over the deficiencies respondent determined for the taxable years ended June 30, 1979, 1980, and 1981.

Accordingly, petitioner's motion to dismiss will be granted as to the taxable year ended June 30, 1978, and denied as to the taxable years ended June 30, 1979, 1980, and 1981. To reflect the foregoing.

An appropriate order will be entered.