Cite as: 534 U. S. 438 (2002)
Opinion of the Court
A
The Commissioner proposes several readings of the statute. First, the Commissioner argues that, because the last sentence of § 9701(c)(2)(A) states that the term "related person" "include[s]" a successor in interest of "any person described in clause (i), (ii), or (iii)," and because these clauses mention the "signatory operator" itself, the signatory operator is "described" in clause (i) by virtue of the express reference. Brief for Petitioner 24.
The text of the statute does not support this reading. Where Congress wanted to include successors in interest, it did so clearly and explicitly. See supra, at 452-453. Each category of "related persons" describes a definitive group of persons. § 9701(c)(2). Congress neither created a separate category for signatory operators nor included signatory operators within these categories. It is unlikely that Congress intended to attach liability to a group such as successors in interest to signatory operators through a general clause that was meant to reach persons "described" in one of three explicit categories.
Second, the Commissioner argues that, under § 9701(c)(2) (A)(i), a signatory operator is necessarily a member of a controlled group of corporations that includes itself. Brief for Petitioner 24. This subsection provides that "related persons" include "a member of the controlled group of corporations (within the meaning of section 52(a)) which includes such signatory operator." § 9701(c)(2)(A)(i). Thus, according to the Commissioner's logic, if corporation A is a member of a controlled group that includes corporations A, B, and C, then a "successor in interest" of a member of the group of corporations A, B, and C includes a successor in interest of corporation A. Ibid.
Standing alone, the subsection supports the Commission-er's argument that a signatory operator is necessarily a member of a group of corporations that includes itself. But this provision cannot be divorced from the clause that begins
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