collateral estoppel and MN adjustments to federal items

Minnesota is perceptibly increasing audits of federal income tax items, e.g. passive activity losses from limited partnerships where the activity of the limited partnership is in a state different from the state residence of the taxpayer.  A question that often arises is the effect of the Minnesota adjustments on federal reporting.  Of course, a fully litigated Minnesota Tax Court or Minnesota District Court tax case likely causes collateral estoppel principles to apply at the federal level (against the taxpayer – in the event of a taxpayer ‘win’ in state court collateral estoppel of course would not run against the United States), but a Minnesota audit followed by simple acceptance by the taxpayer (or even a litigation settlement with Minnesota) likely does not create collateral estoppel effect.