תניא רבי אליעזר הגדול אומר מפני מה הזהירה תורה בל"ו מקומות ואמרי לה במ"ו מקומות בגר מפני שסורו רע
It has been taught: R. Eliezer the Great said: Why did the Torah warn against [the wronging of] a proselyte in thirty-six, or as others say, in forty-six, places? Because he has a strong inclination to evil.<span class="x" onmousemove="('comment',' So Rashi in Hor. 13a. Jast.: because his original character is bad — into which evil treatment might cause him to relapse.
');"><sup>24</sup></span> What is the meaning of the verse,<i> Thou shalt neither wrong a stranger, nor oppress him; for ye were strangers in the land of Egypt</i>? It has been taught: R. Nathan said: Do not taunt your neighbour with the blemish you yourself have.<span class="x" onmousemove="('comment',' Thus be translates the verse: Do not wrong a proselyte by taunting him with being a stranger to the jewish people seeing that ye yourselves were strangers in Egypt.
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Tosafot on Bava Metzia
And some say 46 - there are those who explain this because they count "because you were strangers in Egypt" and similar ones.
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Shita Mekubetzet on Bava Metzia
And some say in 46 places: If you would say, "Where do we find these 46 places? Do we not find above only 3 negative commandments?" One could say that Rabbi Eliezer counted all the places where "stranger" is mentioned, such as "you were stragers" and "you shall love the stranger" etc. Thus taught the RaP (R. Perez ben Elijah of Corbeil). But the RAVaD (R. Abraham ben David) wrote: "It seems to me that every place Scripture mentions 'a stranger' or 'as a stranger' or 'as a citizen' etc. - he counts as a mention. But it appears to me that the count is only 36 and not 46, and the disagreement between these counts is due to the fact that one considers all the places where a stranger is mentioned, while the other excludes these same places in Torah where 'poor,' 'orphan,' and 'widow' are [also] mentioned."