Are Note (plaintext) fields supported in subForms?

I do not see the Notes field as an option for a subForm field.
I was able to add it to the form field definition in code without error but it ignores the new field of type plaintext.

I could not find this listed in the subForm known issues and limitations paper, is this documented?
Also here is a forum entry from support saying there is no restriction on subForm fields.
So there is some confusion.

thanks, tt