Depends on your definition of "tier".
I use the term "tier" to mean a physical separation which means its on different hardware or in a different application space/process boundary (eg. Web Server, Application Server, DB server).
So the data tier would be the physical database application, and my answer would be yes.
I use the term "layer" to represent different abstract boundaries for separation in code ( Presentation, Business Logic, Data Access).
So the data layer would be the DAL code, and my answer would be no, because the application code for DotNetNuke resides in the application space of the web application, which is on the web server.
Looking at it this way, DotNetNuke is not a three tier application, it only has two tiers (Web Server and DB Server) where the Business Logic Layer and the Data Access Layer can not be physically separated.
Most web applications are built this way, unless you go to a Service Oriented Architecture (SOA), which would allow you to access the the business logic and the data access logic through a web Service or through remoting. DotNetNuke does not support this type of architecture today.
Before anyone says that DotNetNuke is to in fact a 3-tier application, I will conceed that argument right away. Most people refer to the web browser as the presentation layer which would be the third tier in DotNetNuke. That is ok, and if we are counting tiers then we can count that one.