No. Clergy receiving a pension from a non-church institution cannot have the institution designate their pension as housing allowance even if contributions to that pension account came as result of the clergy’s employment by a church. The IRS has provided private letter rulings to denominations regarding the designation of annuity payments and other distributions from the denominations’ pension plans. There is no private letter ruling from the IRS that allows non-church institution to designate its pension as housing allowance