If no restrictions on any part of the land or any awkwardness to the piece, I would think not.
A committee at our club tried to tell us ("No possible forseeable use for 62 acres") that we could not have 9 holes on 60 acres while trying to sell us a white elephant clubhouse expansion (so sell the land, can't do anything else!). Bollocks!
With sterling examples such as Merion, Wanamoissett and Metacomet all under 100 acres and 18 holes each, I think 60 for 9 holes with the above caveats should be very doable.
For example, given Lehigh's 60 acres I drew out 9 holes of 3500+ yards with comfortable separation (sans trees) to route a Redan, Bottle, Long, Eden, Sahara, Double Plateau, Road, Knoll and (I forget
the 9th off-hand ) no problem (all with appropriate width).
Keep us posted, Mark.