A notice of deficiency is a prerequisite of tax court jurisdiction. Rule 13, Rules of Practice and Procedure of the United States Tax Court, 26 U.S.C. § 7453; Commissioner v. Gooch, 320 U.S. 418, 420, 64 S.Ct. 184, 88 L.Ed. 139 (1943); Magness v. Commissioner, 334 F.2d 759 (4th Cir. 1964); DaBoul v. Commissioner, 429 F.2d 38 (9th Cir. 1970). To qualify as a notice of deficiency, while a document need not assume any particular form, Commissioner v. Forest Glen Creamery Co., 98 F.2d 968, 971 (7th Cir. 1938), cert. denied, 306 U.S. 639, 59 S.Ct. 487, 83 L.Ed. 1039 (1939); Olsen v. Helvering, 88 F.2d 650, 651 (2d Cir. 1937), nevertheless, it must meet certain substantial requirements.

Charles F. Johnston, Jr., 52 T.C. 792, affd. 429 F.2d 804 (C.A. 6); and see cases cited therein. ‘The issuance of a statutory notice of deficiency by the Commissioner * * * is necessary before the Tax Court has jurisdiction,‘ DaBoul v. Commissioner, 429 F.2d 38; Magness v. Commissioner, 334 F.2d 759; Page v. Commissioner, 297 F.2d 733. Here, no notice of deficiency (or of a transferee liability) has been issued to Transit, Inc.