Whether a net operating loss carryover to a future year that is an 'affected item' under the TEFRA Partnership audit regime can be included within the definition of a 'net loss from partnership items' for purposes of former 26 U.S.C. §6234(a)(3)

QUESTIONS PRESENTED 1. Whether a net operating loss carryover to a future year that is an “affected item” under the TEFRA Partnership audit regime can be included within the definition of a “net loss from partnership items” for purposes of former 26 U.S.C. §6234(a)(3), given that the definitions of “partnership items” and “affected items” are mutually exclusive. 2. Whether the submission of unsigned partnership tax returns and unsigned personal tax returns of the partners to the IRS and the Tax Court was sufficient for the Tax Court to acknowledge the asserted partnership losses reflected on those returns for purposes of resolving the partners’ Tax Court case.