phenotype = genotype + other contributing factors (environment)
Reliability of wikipedia notwithstanding,
http://en.wikipedia.org/wiki/Genotype-phenotype_distinction
Two plants with the same genotype (clones) can actually exhibit different phenotypes in the field.
Now, if you really want to make the distinction is kind of up to how much science you like to drag into your gardening. I like things technical, but I don't think I'm in the majority here.