@jamesave esave. Although others have discouraged this approach if you want to do it, it is very easy to do. I do not see much of an issue. Only requires a single subform and a tab with a "large" amount of tabs to handle the max possible.
The OP stated there will be a max of 4 items per order so they will not need to dynamically create controls.
1. Build the main form
2. Build a subform for items
3. Build the tab control. Add a reasonable amount of tabs.
5. Add the items subform but do not embed it in the page. Instead float it over top of the tab control.
6. On the main forms current event. Configure the tabs by reading the number of child records. Show the appropriate amount of child records and label the tabs.
7. On the tabs change event filter the subform based on which tab is showing.
add a unbound textbox on the main form. Link the subform control to the unbound text box.
When change the tab set the value of the textbox to the correct record and the subform will filter to that.
This example can do up to 20 Partners in a firm.