The Gemara clarifies this ruling: Whom did you hear that said the tithe year of an etrog follows the time of the picking of its fruit? It was Rabban Gamliel. And yet this baraita is teaching that the new year for tithing an etrog is the fifteenth of Shevat, against the opinion of Rabba bar Rav Huna, who says that according to Rabban Gamliel it is the first of Tishrei.

Rather, if this was said, it was said as follows: Rabba bar Rav Huna said: Even though Rabban Gamliel said that the tithe year of an etrog follows the time of the picking of its fruit, like a vegetable, its new year is in Shevat, like a tree.

The Gemara asks: What is different there, in the baraita with regard to one who picked vegetables on the eve of Rosh HaShana, such that it teaches the case when it was the second year of the Sabbatical cycle going into the third year, and what is different here, in the baraita dealing with one who was picking the fruit of an etrog tree on the eve of the fifteenth of Shevat, such that it teaches the case when it was the third year going into the fourth year? Why is the same example not brought in both cases?

The Gemara answers: It teaches us a matter in passing, that it is damaging for an etrog when the tree is handled, and since everyone handles it in the Sabbatical Year, as all the orchards are declared ownerless and everyone is permitted to enter and pick produce, the tree does not bear fruit that is fit for eating for another three years.

Rabbi Yoḥanan inquired of Rabbi Yannai: With regard to an etrog, when is its new year? Rabbi Yannai said to him: It is in Shevat. Rabbi Yoḥanan asked again: Are you referring to the lunar month of Shevat or to the Shevat of the solar season, which begins thirty days after the winter solstice, but on a different date each year? Rabbi Yannai said to him: I am referring to the lunar month of Shevat.

Rava inquired of Rav Naḥman, and some say that it was Rabbi Yoḥanan who inquired of Rabbi Yannai: If it was a leap year, what is the halakha? Does the new year for trees then move to the First Adar, which is the penultimate month in a leap year? He said to him: Follow the majority of years. Even in a leap year the new year for trees is in Shevat.

Rabba said: An etrog from the sixth year of the Sabbatical cycle that entered into, and was picked in, the Sabbatical Year is exempt from tithes, like the produce of the Sabbatical Year, and is also exempt from the mitzva of elimination of Sabbatical Year produce from one’s house after produce of that particular species is no longer found in the field. A Sabbatical Year etrog that entered into, and was picked in, the eighth year is exempt from tithes but is subject to the mitzva of elimination of Sabbatical Year produce from one’s house.

Abaye said to him: Granted, in the latter clause the halakha follows the more stringent approach, as it follows the time of the formation of the fruit, which was in the Sabbatical Year, and therefore the etrog is subject to the mitzva of elimination. But in the first clause, which states that the etrog is exempt from the mitzva of elimination, why is this so? It must be that we say to follow the time of the formation of the fruit, which was in the sixth year. But if so, it should be subject to tithes.

Rabba said to him: Everyone’s hand is touching it, as all are permitted to enter the orchards and touch all the fruit, and so the etrog is regarded as ownerless, and yet you wish to say that it should be subject to tithes? Even if it is not exempt as fruit of the Sabbatical Year, it is exempt from tithes because it is now ownerless.

Rav Hamnuna argued and said: An etrog from the sixth year of the Sabbatical cycle that entered into, and was picked in, the Sabbatical Year is always and for all purposes considered sixth-year produce. And an etrog from the Sabbatical Year that entered into, and was picked in, the eighth year is always and for all purposes considered produce of the Sabbatical Year.

The Gemara raises an objection from the following baraita: Rabbi Shimon ben Yehuda said in the name of Rabbi Shimon: An etrog from the sixth year that entered into, and was picked in, the Sabbatical Year is exempt from tithes, and it is also exempt from the mitzva of elimination of Sabbatical Year produce from one’s house, as there is nothing that is subject to tithes unless it both grew at a time of obligation in tithes and was also picked at a time of obligation. Likewise, an etrog from the Sabbatical Year that entered into, and was picked in, the eighth year is exempt from tithes, and it is also exempt from the mitzva of elimination, as nothing is subject to the mitzva of elimination unless it both grew in the Sabbatical Year and was also picked in the Sabbatical Year.

The Gemara notes: The first clause of this baraita poses a difficulty with regard to the opinion of Rav Hamnuna, who says that a sixth-year etrog that was picked in the Sabbatical Year is subject to tithes. And the latter clause of the baraita poses a difficulty with regard to the opinions of both Rabba and Rav Hamnuna, as they both say that a Sabbatical-Year etrog that was picked in the eighth year is subject to the mitzva of elimination.

The Gemara answers: The matter is a dispute between tanna’im, as it is taught in a baraita: Rabbi Yosei said: Avtolemos testified in the name of five Elders: An etrog follows the time of its picking in the matter of tithes. But our Sages voted in Usha and said that an etrog follows the time of its picking, both in the matter of tithes and in the matter of the Sabbatical Year.

The Gemara raises a question about this baraita: Who mentioned anything about the Sabbatical Year? The subject of the discussion was tithes.