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Anything relating to DOS on NT runs in a virtual dos machine. The comparison is really in the utilites. Some old DOS utilites like the great and powerful EDLIN were exactly the same. With a host of others. Does that make the argument that NT was built on DOS. Based on past experience I would say it's built on Novell more than anything. Even Unix. :) But then again Novell was build on Unix eh?
Unless Windows is written in assembler, it's got too owe something too UNIX. C and all things taken from it were made FOR UNIX. UNIX was then re-written in C, which was very significant, it made it portable. No more Processor and hardware specific coding for OSs was needed. And again, C was made for UNIX.
To my knowledge Windows is written in C. At least some dude at MS told me that a few years ago.
I heard it was a combination of ASM (for the boot process) and C, C++, and VB for everything else.