Quoting%20commentary for Zevachim 199:8

לאו ש"מ כאן קודם חצות כאן לאחר חצות

Hence you must surely infer that one holds good [where the person died] before midday, and the other where he died after midday.<span class="x" onmousemove="('comment',' Cf. p. 479. n. 6.');">¹⁵</span> Whence [does this follow]? Perhaps I can argue that in truth both refer to after midday, but one agrees with R'Ishmael and the other with R'Akiba.

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