Only Ministers for Tax Purposes are eligible for a housing allowance on their ministerial earnings. Church custodians, secretaries and ministerial staff who are not Ministers for Tax Purposes are not eligible for a housing allowance.
A church may call someone a minister, but the IRS may not treat that person as a Minister for Tax Purposes — that depends on individual facts and circumstances. The IRS will consider most ordained ministers to be Ministers for Tax Purposes and therefore eligible for a housing allowance on their ministerial income. Licensed and commissioned ministers are less likely to be treated as Ministers for Tax Purposes by the IRS, but it depends on their individual facts and circumstances. For more information about who is a Minister for Tax Purposes, see our annual Ministers' Tax Guide or Ministerial Tax Issues brochure (which can be found on the same page as the Tax Guide, under the Additional Resources tab).