Two years ago, Corporation M loaned $80,000 to its employee Mr. E. The corporation received Mr. E's properly executed note in which he promised to repay the loan at the end of seven years and to pay annual interest of 9 percent (the market interest rate on the date of the loan). This year, when interest rates were 6 percent, Corporation M sold the $80,000 note to an unrelated party for $92,700.