As a practical matter, most ordained Southern Baptist ministers serving churches will pass either the Knight or Wingo tests, so this question is not that important to them. Many licensed and commissioned ministers could not pass either test, so this question is not that important to them either. Ministers who could pass the Knight test but not the Wingo test should consider consulting their own tax advisers before treating themselves as ministers for tax purposes. After consulting an attorney or accountant, these ministers may decide to follow the Knight test and consider themselves ministers for tax purposes. Nevertheless, they need to be aware that they could be audited and the IRS could take a different position.
Churches have different payroll reporting obligations for ministers and non-ministers.
Churches have to pay FICA for their non-ministerial employees. Ministers are always considered self-employed for Social Security purposes. Their churches cannot pay FICA for them. The church can designate a tax-free housing allowance for ministers only. No, at least not in connection with a ministerial position.