Quite honestly, the vast majority of "realism fanatics" that I've "spoken" to grossly misunderstand the number of non-manuvering fighters killed by surprise bounces.
They quote that statistic (I've never even seen the original sourcing for it, I wonder if it isn't simply an off hand statement that has been passed on as fact, like the mythical 15mm machineguns in the Bf109K-4's cowling) that says something like 90% of guys shot down never saw the guy that got them.
That by no means indicates that 90% of the pilots that got shot down were flying along on cruising power when , suddenly they were shot down.
What it means is that they were involved in what they were doing, almost always in a fight and trying to get a shot on somebody (hey, we've all done it, its called target fixation, they were hardly immune to it in the real deal) when somebody they weren't watching got a shot on them. It happens to all of us in these sims. Not as often surely, but it does happen with some frequency.
Adding the assumption of level flight adds information to the statment that isn't there. It adds assumptions.
Now, going on the books on Aces I have read, Sakai's and Tuck's spring to mind, relatively few of their kills were on people flying level. Tuck's first kill was, and he was bounced while doing the same in his Hurri IIc (though less successfully from the enemy's viewpoint) and I can only think of the P-39 Sakai broke in half from his book. On the other hand, both books described numerous kills in which the enemy was manuvering and at combat power, but simply didn't see Tuck or Sakai.