On November 6, 2019, Alisha Thomas, a cash basis taxpayer, received a promissory note from a client in the amount of $120,000. The note bore interest at the then market rate, was fully negotiable, not subject to setoffs, and could have been sold for $84,000 to a local bank which in determining this amount took into account the maker's credit profile. In preparing her 2019 tax return, Alisha did not include any part of the $120,000 in her gross income. On May 12, 2021, the Service commenced and audit of her 2019 tax return and ultimately made a timely audit adjustment including $120,000 in her 2019 taxable income. Assuming Alisha wishes to contest the audit adjustment, advise her as to the arguments available to her and assess her chances of success. Fully explain your