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Mishneh Torah, Second Tithes and Fourth Year's Fruit 8-10
Sugya Map
The halakhic matrix of Hilchot Ma'aser Sheni u-Neta Reva'i Chapters 8–10 addresses the metaphysical boundaries of sacred property (hekdesh / ma'aser) as they intersect with the messy, fluid realities of commercial transactions, currency fluctuations, and agricultural growth. The sugya bifurcates into two primary domains: first, the mechanics of p'dut (redemption) and kinyan (acquisition) of Ma'aser Sheni; second, the ontological status and calculation of Neta Reva'i (fourth-year produce).
Core Tensions & Inquiries
- The Ancillary Sanctity Problem (Taflo shel Hekdesh): When a person buys a consecrated commodity (such as wine or a sacrificial animal), does the sanctity of the Ma'aser Sheni money expand to capture the vessel or the hide (kankan and or)?
- The Temporal Mechanics of Redemption (She'at Halchalot): When currency values shift during a rolling redemption, or when agricultural prices fluctuate between the moment of physical acquisition (meshichah) and monetary payment (kesef), at which point does the metaphysical transfer of kedushah crystallize?
- The Legal Identity of Neta Reva'i: Is Neta Reva'i an extension of the agricultural prohibition of Orlah, or is it a positive species of Ma'aser Sheni? Is it classified as divine property (mamon gavoah) or private property (mamon be'alim)?
Nafka Minot (Practical and Conceptual Ramifications)
- Metaphysical Containment: If a container or hide becomes kadosh (holy) as an accessory to the food, must its value be eaten under the strictures of Ma'aser Sheni in Jerusalem, or does it retain its mundane status (chullin)?
- Risk of Price Fluctuations: If a transaction is initiated with Ma'aser Sheni funds and the market value of the crop shifts prior to completion, who bears the burden of adding chullin funds, and who captures the "sacred surplus"?
- The Geographic Scope of Obligation: If Neta Reva'i is fundamentally tied to Orlah, it should apply globally by rabbinic decree (halacha le-Moshe mi-Sinai); if it is tied to Ma'aser, it should be restricted to the boundaries of Eretz Yisrael.
Primary Sources
- Mishnah: Mishnah Ma'aser Sheni 1:3, Mishnah Ma'aser Sheni 2:4, Mishnah Ma'aser Sheni 3:12-13, Mishnah Ma'aser Sheni 4:6-8, Mishnah Ma'aser Sheni 5:1-5, Mishnah Orlah 1:1-9.
- Talmud Bavli: Eruvin 27b (deriving vessel inclusion), Bava Metzia 45b (currency definitions), Bava Kama 69a (marking fields in Shemitah), Kiddushin 54b (status of Ma'aser as mamon gavoah).
- Talmud Yerushalmi: Yerushalmi Ma'aser Sheni 2:10 (the mechanics of retroactive designation).
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Text Snapshot
The conceptual anchor of the Rambam's formulation of ancillary acquisition is found in Hilchot Ma'aser Sheni 8:1:
"הַלּוֹקֵחַ חַיָּה לְשַׁלְמֵי שְׁלָמִים, אוֹ בְּהֵמָה לִבְשַׂר תַּאֲוָה מִמִּי שֶׁאֵינוֹ תַּגָּר וְאֵינוֹ מְדַקְדֵּק—יָצָא הָעוֹר לְחֻלִּין... מִן הַתַּגָּר—לֹא יָצָא הָעוֹר לְחֻלִּין."[^1]
Linguistic & Grammatical Nuances
- "מִמִּי שֶׁאֵינוֹ תַּגָּר וְאֵינוֹ מְדַקְדֵּק" (From one who is not a merchant and is not precise): The double formulation (eino tagar and eino medakdek) is not mere pleonasm. As Rav Adin Steinsaltz notes, the hediot (layman) operates on a macro-valuation of the transaction; he prices the transaction based on the meat alone ("קובע את המחיר רק על פי הבשר")[^2]. The Rambam's syntax implies that the status of the hide is not determined by an objective, inherent law of physical attachment, but rather by the subjective financial mindfulness (da'at) of the parties to the transaction.
- "יָצָא הָעוֹר לְחֻלִּין" (The hide goes out to non-sacred status): The word yatzah (goes out) is highly precise. It implies that initially, because the hide is physically bound to the animal purchased with Ma'aser funds, we might have assumed it was swept into the net of kedushah. The Rambam rules that the layman's indifference acts as a conceptual severing agent, allowing the hide to "exit" to chullin without requiring redemption (pidyon)[^3].
- "פִדְיוֹן מַעֲשֵׂר שֵׁנִי כִּמְשִׁיכָה" (The redemption of second tithe is like pulling): In 8:10, the Rambam equates the metaphysical mechanism of pidyon to the physical act of meshichah.[^4] This comparison is highly unusual: meshichah is a civil kinyan, whereas pidyon is a ritual translation of sanctity. The Rambam's choice of words indicates a profound synthesis of civil property law and temple law.
Readings
The conceptual architecture of these chapters has generated rich debate among the Rishonim and Acharonim. We will explore three major readings that dissect the underlying mechanisms of these laws.
Reading 1: The Subjective-Intent vs. Objective-Value Model of Ancillary Sanctity (Tagar vs. Hediot)
The Rambam rules in 8:1 that if one buys an animal from a non-merchant, the hide is chullin, but if bought from a tagar (merchant), the hide remains holy.[^5]
The Chiddush of the Kessef Mishneh & Radbaz
The Kessef Mishneh[^6] and the Radbaz[^7] ground this distinction in the subjective intent of the seller (da'at makneh). In a standard transaction, the meat is the primary object of the sale (ikkar), and the hide is secondary (tafel). When dealing with a hediot (layman), who is not meticulous, he waives his claim to the precise value of the hide. He views the hide as a costless byproduct of the meat sale. Therefore, the Ma'aser Sheni money paid by the buyer is considered to have been exchanged solely for the meat. The hide is, in effect, a gift (matanah) from the seller. Because no Ma'aser funds were paid for the hide, no sanctity can devolve upon it.
Conversely, a tagar calculates his margins down to the penny. He does not give gifts. When he sells the animal, the price is a composite of both the meat and the hide. Because a portion of the Ma'aser money was objectively allocated to purchase the hide, the hide is captured by the sanctity of the money.
The Brisk Analysis (Rav Chaim Soloveitchik)
Rav Chaim Soloveitchik[^8] refines this dynamic by posing a fundamental question: Is the hediot's waiver a transfer of ownership via gift, or is it an objective redefinition of the transaction's focus?
Rav Chaim suggests that under the laws of Ma'aser Sheni, sanctity does not merely follow the path of civil acquisition (kinyan); it follows the path of allocation (shuyam). If the hediot does not value the hide, then in the market reality of this transaction, the hide has no independent price. It is treated as non-existent (ke-man d'leita). Therefore, the sanctity of the money is concentrated entirely within the meat. For the tagar, however, the hide has an independent market identity. It cannot be treated as a mere accessory. Thus, the transaction is legally split into two purchases: a purchase of meat and a purchase of hide.
This leads to a fascinating nafka mina (conceptual difference): If a buyer purchased an animal from a hediot, but the buyer explicitly stated that he was buying the animal specifically for its high-quality hide, would the hide become holy? According to the Kessef Mishneh's model of da'at makneh (seller's intent), it might remain chullin because the seller did not care to charge for it. However, according to Rav Chaim's model of objective transaction profiling, the buyer's explicit focus gives the hide an independent identity within this specific transaction, thereby capturing it within the net of Ma'aser sanctity.
Reading 2: The Ontology of Currency Fluctuation (Dinar shel Ma'aser)
In 8:7, the Rambam addresses a case where a person sets aside a dinar of Ma'aser money to gradually redeem food against it, and the exchange rate of the coin subsequently fluctuates.[^9] If the dinar was worth 20 me'ah, and after consuming 10 me'ah of food, the coin's value inflated to 40 me'ah, the owner must now spend another 20 me'ah of food to free the coin.
Initial State: 1 Dinar = 20 Me'ah.
[████████████████████] (20 Me'ah of Sacred Value)
Step 1: Consume 10 Me'ah of food.
[██████████] [░░░░░░░░░░] (10 Me'ah redeemed / 10 Me'ah remaining)
Step 2: Currency Inflates. 1 Dinar now = 40 Me'ah.
The remaining half of the physical coin now commands 20 Me'ah of purchasing power.
[████████████████████] (20 Me'ah of Sacred Value must now be redeemed)
The Chiddush of the Rashba and Tosafot
This ruling exposes a deep dispute regarding the nature of money (matbe'a) in the laws of redemption. The Tosafot[^10] and the Rashba[^11] ask: If half of the coin's sacred value was already successfully transferred to the first 10 me'ah of food, why should the subsequent inflation of the remaining physical silver retroactively increase the owner's obligation? If the remaining sacred charge was 10 me'ah, it should remain 10 me'ah, regardless of how the market values the silver.
The Rambam's Model: "The Nominalist Currency Theory"
The Rambam operates on a nominalist theory of currency. A coin designated for Ma'aser is not merely a physical lump of silver containing a static quantum of holiness. Rather, the coin represents a dynamic legal credit of purchasing power.
When the Torah dictates that Ma'aser is redeemed with "money," it requires that the physical instrument used for redemption possess the status of currency (matbe'a). The primary characteristic of currency is its face value as determined by the current market. Consequently, the holiness is bound to the fractional purchasing power of the coin, not to its static silver weight.
When half of the coin's value was redeemed, the coin was split conceptually: 50% became chullin and 50% remained kadosh. When the coin's market value inflated to 40 me'ah, that remaining 50% of the physical coin now commanded 20 me'ah of purchasing power. Because the holiness is bound to the physical coin's currency status, the outstanding sacred debt naturally rises to match the new market reality. The Rambam views the coin as a single, indivisible vessel of kedushah whose internal pressure rises and falls with the tides of the market.
Reading 3: Neta Reva'i—Inherently Holy or Mimetic Sanctity?
In Hilchot Ma'aser Sheni 9:1–2, the Rambam defines Neta Reva'i (fourth-year fruit) as being "holy" and states that "the law applying to it is that it must be eaten in Jerusalem... in the same way as the second tithe."[^12]
The Chiddush of the Ramban
The Ramban[^13], in his commentary on the Torah Leviticus 19:24, argues that Neta Reva'i is fundamentally different from Ma'aser Sheni. Ma'aser Sheni is a human-initiated tithe; the fruit only becomes holy when the owner designates it as such (tikkun). Neta Reva'i, by contrast, is inherently holy from the moment it grows (kedushah me-rechem). It is an agricultural extension of the Orlah prohibition. The Torah simply permitted this forbidden fruit in its fourth year by requiring it to be redeemed or eaten in Jerusalem.
The Rambam's Conceptual Synthesis
The Rambam, however, champions a unifying theory. He positions Neta Reva'i not as a cousin of Orlah, but as a twin of Ma'aser Sheni. To the Rambam, the holiness of Neta Reva'i is functionally identical to Ma'aser Sheni. This is why he integrates the laws of Neta Reva'i directly into Hilchot Ma'aser Sheni, rather than placing them in Hilchot Ma'achalot Assurot (Forbidden Foods) alongside Orlah.
This conceptual alignment yields a major ruling: Just as Ma'aser Sheni is exempt from the poor-man's gifts (leket, shikhcha, and pe'ah) because it is "the property of the Most High" (mamon gavoah), so too is Neta Reva'i exempt from these gifts.^14
Furthermore, the Rambam rules that Neta Reva'i does not apply in Syria or in the Diaspora.^15 If Neta Reva'i were merely the final stage of Orlah, it should apply globally, just as Orlah applies globally by rabbinic tradition. By exempting the Diaspora, the Rambam cements his view: Neta Reva'i is a species of Ma'aser, bound to the agricultural sanctity of the Land of Israel, rather than a personal prohibition bound to the tree itself.
Friction
The Clash: The Paradox of Meshichah vs. Money in Ma'aser Redemption
A major internal tension in the Rambam's system emerges when comparing his rulings on price fluctuations in Ma'aser Sheni transactions.
In 8:8, the Rambam rules:
If a person purchases produce with a sela of Ma'aser money and performs meshichah (pulling the produce into his domain) but does not pay the seller before the market price of the produce doubles to two selaim, the buyer pays only one sela. The Rambam declares: "The profit is realized by the second tithe" ("הַשָּׂכָר לַמַּעֲשֵׂר").[^16]
In 8:10, however, the Rambam writes:
"פִדְיוֹן מַעֲשֵׂר שֵׁנִי כִּמְשִׁיכָה" (The redemption of second tithe is like pulling).[^17] This means that the payment of money to redeem Ma'aser is the act that finalizes the transfer of holiness, operating with the same legal finality as meshichah does in a standard civil transaction.
The Kushya (The Ra'avad's Attack)
The Ra'avad[^18] immediately exposes a deep contradiction here. If "redemption of Ma'aser is like meshichah"—meaning that the payment of money is the primary metaphysical trigger that transfers the holiness—then in the case of 8:8, where the buyer performed meshichah but did not yet pay, the holiness should not yet have transferred to the produce!
If the holiness has not yet transferred, how can the Rambam claim that "the profit is realized by the second tithe" (meaning the entire volume of now-doubled produce is consecrated as Ma'aser)?
At the moment the price rose, the buyer had only performed a civil meshichah; no Ma'aser money had changed hands. If civil meshichah does not effect redemption, the produce should still be ordinary chullin, and the subsequent payment of the one sela of Ma'aser money should only consecrate half of the now-expensive produce (i.e., one sela's worth of the current market value, which is now only half the pile).
Why does the Rambam consecrate the entire pile, forcing the buyer to eat two selaim's worth of produce in Jerusalem, when he only paid one sela of sacred funds?
Timeline of the Transaction:
[Time T1] ───> Buyer performs Meshichah of 1 bushel (Value: 1 Sela). No payment made.
Status: Civil transaction complete. Metaphysical redemption pending.
[Time T2] ───> Market Spikes. 1 bushel is now worth 2 Selaim.
[Time T3] ───> Buyer pays 1 Sela of Ma'aser Sheni money.
Rambam's Verdict: The ENTIRE bushel is consecrated (Value: 2 Selaim).
Ra'avad's Objection: Only HALF the bushel should be consecrated!
The Terutzim
Terutz 1: The Dual-Track Theory of Kinyan (The Kessef Mishneh's Resolution)
The Kessef Mishneh[^19] resolves this by splitting the transaction into two distinct legal tracks: the civil track (kinyan mamoni) and the sacred track (kinyan hekdesh).
Under civil law, the moment the buyer performs meshichah, the transaction is finalized. The seller can no longer back out, and the buyer owes a debt of one sela. Although Rabbinic law generally maintains that money acquires (kesef koneh) and meshichah is merely a Rabbinic safeguard, in the case of Ma'aser, the Torah explicitly states: "And he shall pay the money and it shall be established for him" Leviticus 27:19.
When the buyer performed meshichah at Time T1, he acquired the physical produce. When the price rose at Time T2, the produce was already civilly his. When he finally paid the one sela of Ma'aser money at Time T3, that payment did not initiate a new purchase; it merely settled the debt incurred at Time T1.
Because the debt was one sela, and that one sela was paid with Ma'aser funds, the sanctity of that sela retroactively floods into the entire physical package that was acquired at Time T1. The "profit" (the increase in value) is captured by the Ma'aser because the physical vessel holding that profit was already locked into the buyer's domain under the original price agreement.
The phrase "redemption of Ma'aser is like meshichah" means that just as meshichah locks in a civil transaction, the payment of Ma'aser money locks in the redemption rate retroactively to the moment the civil transaction was finalized.
Terutz 2: The Rogatchover Gaon's Ontological Distinction (Tzofnat Paneach)
The Rogatchover Gaon[^20] offers an elegant metaphysical distinction between Kinyan she-ba-guf (acquisition of the physical object) and Kinyan she-ba-kedushah (acquisition of the sacred status).
The Rogatchover argues that meshichah without money is sufficient to bind the guf (the physical substance) of the produce to the buyer. However, the kedushah (sanctity) of the Ma'aser money requires the actual transfer of the coins to take effect.
When the Rambam states "the profit is realized by the second tithe," he is addressing a unique halakhic reality: once the buyer's physical action (meshichah) has linked his destiny to this specific pile of produce, any subsequent growth in the value of that produce is legally considered an "organic growth" (shevach) of the object itself.
In the laws of sacred property, an organic growth of an object that is destined for consecration is automatically consecrated along with it. Because the buyer was legally obligated to complete this transaction using Ma'aser money, the produce was already "designated for sacred use" (m'zuman le-hekdesh). Therefore, when the value of the produce grew, the growth occurred within a semi-sacred state. When the money was finally paid, it merely finalized the active status of the sanctity, capturing the organic growth that had accrued in the interim.
Intertext
To understand the broader implications of these mechanisms, we must examine how they interface with other fields of halakha.
Parallel 1: The Merchant/Non-Merchant Standard in Choshen Mishpat
The distinction the Rambam draws in 8:1 between a tagar (who is precise) and a hediot (who is not) in determining whether an accessory is included in a sale is not unique to Ma'aser. It serves as a foundational heuristic in the laws of commercial error (Ona'ah and Mekach Ta'ut).
In Hilchot Mechirah 13:3–4, the Rambam addresses the laws of price fraud:[^21]
If a standard merchant (tagar) overcharges by more than one-sixth, the transaction is void. However, if a private individual (hediot) sells his personal items, the laws of Ona'ah are significantly relaxed, or, according to some opinions, do not apply at all if it is clear he was simply clearing out his home.
We see a unified conceptual approach across both Choshen Mishpat (civil law) and Zera'im (agricultural law):
| Dimension | The Private Layman (Hediot) | The Professional Merchant (Tagar) |
|---|---|---|
| Commercial Intent | Focuses on the core transaction; waives precision on minor details (vattaranut). | Meticulous calculation of every asset; no waiver of value. |
| Ancillary Assets (8:1) | Hide/vessel is treated as a free gift; remains chullin.[^22] | Hide/vessel is priced into the sale; captured by Ma'aser sanctity.[^23] |
| Price Fraud (Ona'ah) | High tolerance for deviation; assumed mutual waiver (mechilah). | Zero tolerance for deviation beyond the legal standard (sh'tut). |
The Rambam uses the gavra (the personality of the transactor) to define the cheftza (the legal boundaries of the transaction). A transaction is not merely an objective exchange of goods for cash; it is a psychological meeting of minds (da'at). The professional status of the seller determines the default assumptions of that mental contract.
Parallel 2: The Double-Cause Rule (Zeh ve-Zeh Gorem) in Orlah and Beyond
In Hilchot Ma'aser Sheni 10:20, the Rambam rules:
"כָּל דָּבָר שֶׁהוּא מִשְּׁנֵי גּוֹרְמִין, אֶחָד אָסוּר וְאֶחָד מֻתָּר—מֻתָּר." (Any entity that is brought about by two causes, one forbidden and one permitted, is permitted.)[^24]
Therefore, if a seed of Orlah (forbidden) is planted in the earth (permitted), the resulting tree and its fruit are permitted. The forbidden seed is not viewed as the sole cause of the new growth; the permitted soil, water, and labor are equal partners in the output.
This rule of Zeh ve-Zeh Gorem (this and that cause it) is a major engine of halakhic analysis, appearing in several key areas:
1. Idolatry (Avodah Zarah)
In Avodah Zarah 48b, the Gemara discusses whether one may use the ashes of an Asherah tree (an idol) to fertilize a field. The Gemara permits the crops grown from this fertilizer because the growth is caused by both the forbidden fertilizer and the permitted soil.
2. Ritual Slaughter (Shechitah)
If an animal is slaughtered using a knife that is partially owned by an idolater and partially by a Jew, or if a physical action is performed jointly by a force of nature and a human, we invoke Zeh ve-Zeh Gorem to permit the result.
The Rambam's inclusion of this rule at the very end of his discussion of Orlah and Neta Reva'i is highly strategic. It serves to limit the reach of agricultural prohibitions. While the Torah is highly protective of the Land's sanctity, it does not allow metaphysical prohibitions to easily contaminate the physical world.
By applying Zeh ve-Zeh Gorem, the Rambam ensures that the forbidden status of Orlah remains confined to the original physical plant. It cannot replicate itself through natural agricultural reproduction, because the earth—which belongs to the Creator—acts as a purifying, permitting agent in every new growth.
Psak/Practice
How do these intricate conceptual frameworks manifest in contemporary halakhic practice, particularly in the modern State of Israel and the Diaspora?
1. The Diaspora Lenient Standard (Safek Orlah)
The Rambam's ruling that Neta Reva'i does not apply in the Diaspora is a major point of discussion in contemporary practice. The Shulchan Aruch Yoreh De'ah 294:7 cites the Rambam's lenient view but notes that other Rishonim (such as the Rashba and Rosh) rule stringently, requiring the observance of Neta Reva'i globally, at least with regard to vineyards.
In practice, the Ashkenazic custom (following the Rema)^25 is to be lenient with regard to non-grape fruit trees in the Diaspora, applying the rule of safek d'rabanan le-hakel (when in doubt regarding a rabbinic law, we rule leniently). For grapes, however, many communities maintain the stringency of Neta Reva'i even outside of Israel.
2. Modern Redemption of Orlah and Reva'i in Israel
In Israel today, where agricultural laws are of paramount importance, the redemption of Neta Reva'i is performed through central halakhic agencies (such as the Beit Din of the Eda Charedit or the Chief Rabbinate).
Following the Rambam's ruling in 9:5 that the redemption must be estimated by three appraisers based on market value,^26 modern authorities have established a highly efficient system:
- Because we no longer have the Temple, the fruit cannot be eaten in Jerusalem.
- Therefore, the fruit must be redeemed.
- To avoid the need for complex, individual valuations of every piece of fruit, the Batei Din set aside a specific coin (often a large silver coin) that has a known, stable value.
- The farmers or consumers transfer the sanctity of their fourth-year produce to a tiny fraction of this coin (a perutah's worth) using the modern equivalent of the rolling redemption described in 8:14 ("הַמַּנִּיחַ דִּינָר... וְהוֹלֵךְ").[^27] Once the coin is full of sanctity, it is formally deselected and retired.
Meta-Psak Heuristic: The Primacy of Da'at
The overarching meta-psak heuristic that emerges from these chapters is the Primacy of Da'at over physical form. Whether determining if a hide is holy, if a coin is redeemed, or if a tree was planted for food or a hedge, the physical reality is subordinate to human intent and market agreement. In the Rambam's view, sanctity is not a physical substance that clings to matter; it is a legal status that is projected onto the physical world through the conscious, structured intent of the human mind.
Takeaway
Sanctity in the Rambam's world is not a static, physical contagion, but a dynamic legal status governed by human intent (da'at) and commercial reality. Whether managing currency fluctuations or the growth of a fourth-year vineyard, the physical world is continually reshaped by the legal frameworks of the Torah.
[^1]: Hilchot Ma'aser Sheni u-Neta Reva'i 8:1. [^2]: Steinsaltz on Mishneh Torah, Hilchot Ma'aser Sheni 8:1:1. [^3]: Steinsaltz on Mishneh Torah, Hilchot Ma'aser Sheni 8:1:2. [^4]: Hilchot Ma'aser Sheni u-Neta Reva'i 8:10. [^5]: Hilchot Ma'aser Sheni u-Neta Reva'i 8:1. [^6]: Kessef Mishneh on Hilchot Ma'aser Sheni 8:1. [^7]: Radbaz on Hilchot Ma'aser Sheni 8:1. [^8]: Chiddushei Rabbenu Chaim HaLevi on Hilchot Ma'aser Sheni 8:1. [^9]: Hilchot Ma'aser Sheni u-Neta Reva'i 8:7. [^10]: Tosafot, Bava Metzia 45b s.v. "Dinar". [^11]: Chiddushei HaRashba, Bava Metzia 45b. [^12]: Hilchot Ma'aser Sheni u-Neta Reva'i 9:1–2. [^13]: Ramban, Leviticus 19:24. [^14]: Hilchot Ma'aser Sheni u-Neta Reva'i 9:4. [^15]: Hilchot Ma'aser Sheni u-Neta Reva'i 9:1. [^16]: Hilchot Ma'aser Sheni u-Neta Reva'i 8:8. [^17]: Hilchot Ma'aser Sheni u-Neta Reva'i 8:10. [^18]: Hassagot HaRa'avad on Hilchot Ma'aser Sheni 8:8. [^19]: Kessef Mishneh on Hilchot Ma'aser Sheni 8:8. [^20]: Tzofnat Paneach on Hilchot Ma'aser Sheni 8:8. [^21]: Hilchot Mechirah 13:3–4. [^22]: Hilchot Ma'aser Sheni u-Neta Reva'i 8:1. [^23]: Hilchot Ma'aser Sheni u-Neta Reva'i 8:1. [^24]: Hilchot Ma'aser Sheni u-Neta Reva'i 10:20. [^25]: Darkhei Moshe, Yoreh De'ah 294. [^26]: Hilchot Ma'aser Sheni u-Neta Reva'i 9:5. [^27]: Hilchot Ma'aser Sheni u-Neta Reva'i 8:14.
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