Likewise, the government of American Samoa, a United States possession, has been deemed to be an agency for purposes of the analogous provision of section 251(j), I.R.C. 1939, the predecessor of the present Code section 931(i). In Bell v. Commissioner, 278 F.2d 100 (4th Cir.), affirming 32 T.C. 839 and 30 T.C. 559, the Court of Appeals concluded that (p. 103): the term ‘agency’ is used in its ordinary and customary meaning and since the Government of American Samoa is under the Department of the Interior, a department of the Federal Government, it is an agency of the United States.