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section 951(a) and (b) reveals that Congress was acutely aware of
the various ways that a taxpayer could be considered to be an
owner of an asset. By incorporating the constructive ownership
rules into section 951(b) (by reference to section 958(b), which,
in turn, references section 318(a)), and excluding the
constructive ownership rules from section 951(a) (by choosing not
to include a comparable reference), Congress prescribed a
specific meaning for the term “owns” in section 951(a). See also
S. Rept. 1881, 87th Cong., 2d Sess. (1962), 1962-3 C.B. 703, 943-
944 (legislative history helps to make clear how direct and
indirect ownership, on the one hand, are distinguished from
constructive ownership, on the other hand, for purposes of the
gross income inclusion required by subpart F). In a case such as
this, where “a statute limits a thing to be done in a particular
mode, it [the statute] includes the negative of any other mode.”
Botany Worsted Mills v. United States, 278 U.S. 282, 289 (1929).
This principle of statutory construction, which reflects an
ancient maxim “expressio unius est exclusio alterius” (the
expression of one thing is to the exclusion of the other), is
applicable here. See Natl. R.R. Passenger Corp. v. Natl.
Association of R.R. Passengers, 414 U.S. 453, 458 (1974); see
also Natl. Truck Equip. Association v. Natl. Highway Traffic
Safety Admin., 972 F.2d 669, 674 (6th Cir. 1992) (“In
interpreting silence, we keep in mind the statutory canon
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