Well yes, but as you really can't determine the MIME type based on anything else except the extension when it comes to ASCII text files, of which some are meant to be run, some displayed as-is and some parsed as HTML by the client, it's mostly the same thing.
And indeed, the file extension is by far easier to spoof, a simple rename operation would do that. MIME types at least require modifying the multipart/form-data headers (it does actually send the MIME type, doesn't it? I don't know my RFC by heart 😉)