this is a limitation to the microsoft Jet database engine.
The microsoft Jet database engine limits the number of output fields that a query can have to 255 columns. Similar to an access table, a query can have no more than 255 columns.
Note on UPDATE queries:
Note also that as the microsoft Jet database engine iterates through the records in an UPDATE query, it creates a field for the original value and a field for the updated value. When more than 127 fields are selected, it reaches the 255 field limit of a query.