Excluding drivers, documentation and non-x86 arch code, Linux is "only" 173mb of uncompressed source (39mb gzipped). The Debian source repository is 103GB compressed, or, put another way, the replaced code amounts to about 0.03% of what makes up Debian.
It would in theory be totally possible with enough work to make Ubuntu run on the FreeBSD kernel, does that mean FreeBSD is Linux?
Linux of the early 00s was popularized on a platform of "Linux is about freedom, Linux is about choice". At least one half of that is entirely due to the distributions.
From a programmer's perspective, you are writing a program which interacts with the world by making system calls to the kernel. So the kernel is fundamentally more relevant than the fact that the system is running Wayland and comes with LibreOffice.
So, not Linux.
export DOCKER_HOST=localhost:2375