Reference for Arakhin 12:37

תלמוד לומר

said: All agree that an oral debt cannot be collected from the heirs, what they are here disputing is the [nature of a] debt arising from the law of the Torah, the first Tanna holding that a debt arising from the law of the Torah is not to be considered equal to one acknowledged in a document [of indebtedness], whilst R'Jose considers it like one acknowledged in a document [of indebtedness].

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