Aha,

I am wrong in assuming COUNT (1) refers to the first column.

SELECT COUNT (25)

--or

SELECT COUNT ('something')

these both return 1, as the count of the literal expression, be it integer or character

Similar to

SELECT 1,2,3,'something' FROM #TEMP

Notice that 1,2,3, and the string above are literals.

Can anyone thing of another instance where you would refer to the ordinal positions of columns as 1,2, or 3... other than and ORDER BY?