To start with some example code:
for (var a = 7 in /7/ in 9 in b);
If I run that in node I get: TypeError: Cannot use 'in' operator to search for '/7/' in 9
As this code is vaguely equivalent to: var a = 7; for (a in ((/7/ in 9) in b));
However, it gets converted by sjs to: for (var a = 7 in (/7/ in (9 in b)));
That's obviously different, and gives this error instead: ReferenceError: b is not defined
(I really should get back to actually doing my job now, though; if dherman responds again I'll totally notice and follow up: that conversation is really interesting to me.)