Create new note and give $Text the focus

When creating a new note in outline or map view, what are the keystroke or action code steps that can be taken to give the newly created note’s $Text the focus?

Assuming the new note is the current view selection, then Opt+Tab toggles focus between view pane and text pane $Text area… If the selected note has Displayed Attributes then the toggle is 3-way: view → $Text → Displayed Attributes table item 1 → view pane.