I went to check my guess and ran:
WITH DATA (Numbers) AS
(SELECT NULL UNION ALL
SELECT NULL UNION ALL
SELECT NULL UNION ALL
SELECT 1 UNION ALL
SELECT 2 UNION
SELECT 3)
SELECT COUNT(ALL Numbers) AS NULLNumberCount FROM DATA
WHERE Numbers IS NULL
and got:
Msg 156, Level 15, State 1, Line 1
Incorrect syntax near the keyword 'WITH'.
Ooops