Given that practically all modern OS'es are 64 bit, and Windows 64 bit can't run 16 bit binaries (Windows 3.x) I suspect not.
It was just an old rumor to explain why it used shit ton of RAM really.
But I've tried to run old Windows and DOS programs, and it says it can't do it. They probably wouldn't have bothered with the 32 bit layer if they thought they could get away with it.
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