Tasha is correct. The distributive property applies, so she can use any factor she likes, even an irrational one.
120 - 36 = 12*10 - 12*3 = 12(10 - 3) . . . . . using the GCF (=12)
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This can also be written
... 120 - 36 = π((120/π) - (36/π)) . . . . . . . . using an arbitrary irrational factor
