I'll take your word on Hymphrey. But is that the only reason that Windows OS requires so much code?
It's my understanding that another, not insignificant reason is because Windows is a Mac-like GUI laminated over DOS. It takes a lot more code to get a GUI that way than Mac does using it's propietary chip architecture.
(We can skip over the whole Xerox thing here. I'll stipulate that Apple mimicked Xerox, popularized the GUI, and that Windows mimicked Mac when they saw it was a commercial success.)