It might be occasionally, but I seriously doubt it could be done first time and every time, which is what it has to do for me to say it is MOA.
With my Swiss K31 and my Remington 30-06 I'm rather picky about the reloads, but the Winchester is only for hunting and fun so I don't work real hard on those loads. A consistent 3 or 4 inch group is fine for what I'm doing with it. Plus like Mountainview, I am fairly old, so the eyes are not all they once were.