That's all crap. Under our plan where I'm eating 6 times a day, I have some protein and a little bit of carbs about a couple hours before I go to bed, regardless of what time that may be. Keeps the metabolism working overnight. I think my plan calls for a tuna sandwich (no mayo, brown bread) at this time.
I eat every 2.5-3 hours, starting whenever I wake up, regardless of the time.