TT,
If it were MSDE or SQL server, you could use the syscolumns table, but there is no 'MSysColumns' table (at least not available to the user) for JET tables. There is MSysQueries, which will list query fields, so you can drop your table fields into a query if you you absolutely had to call this via sql.
Otherwise you could still use the dao tabledefs object in a function that returns the list of fields as a single string. For stuff like this you might create a dummy table--Oracle called theirs 'dual', and you could use functions by doing "Select MyFunction from dual". Sql server allows a SELECT without a table, but this is moot because with SQL Server you have the syscolumns at your disposal.
--Jim