Hi Paul
In theory, the answer to that question should be "32" - no matter how many users you can REALLY get on the server, you still should always follow JDE sizing recommendations - which haven't been adjusted for the new technologies or for 64bit.
However, with a 64bit Windows 2003 machine and with a true 16Gb of available memory - providing the processing power is available (say, with two quad core 3.0GHz processors giving 8 cores) - then I wouldn't have any hesitation to being able to see around 250 concurrent users before seeing severe problems. Its easy to calculate - an Xe user uses approximately 50Mb of memory per session. Add an additional 10Mb for other overheads with the OS - and you're looking at 60x250=15Gb - with extra memory left over for operating system processes and overhead for redundant scalability (in case another Terminal Server fails for example).
HOWEVER, there are some caveats.
First of all, when you start loading on the number of users - then you're going to move the bottleneck away from CPU and Memory - and you're going to start to see bottlenecks at the NIC level (Network card). So, obviously ensure you have multiple Gigabit connectivity to the database - since 250 concurrent sales order entry users could be generated 2Gigabit/s in network traffic - and you're going to have some major impacts all over your architecture to support that.
Also, again depending on the functionality used and the frequency of the users performing tasks, you're going to have some bottlenecks on the local disk performance. I like using RAID5 with 15K RPM SCSI3 drives over several arms with the OS on a seperate mirrored partition - but I have seen some really badly configured drive setups for terminal servers. Remember, you're reading the spec files from the disk - and the performance of opening those spec files 250 times is going to incur some huge impacts.
I still prefer to size smaller boxes - and have more of them available to me. It provides redundancy, a better method of architecting individualistic paths, and, to be honest, is a lot, lot less expensive than purchasing a single "large" server. Just because its theoretically possible to get your entire user base onto a single box, doesn't mean its a good idea !