I really doubt it's a Windows issue.
It's almost certainly hardware related, i'd say.
My first guess would be RAM.
I know you've memtested, etc., but i've done that too, only to still have issues.
Could be a bad RAM slot. Try different slots, or just one dimm for a while to see if it continues.
It could be a drivers conflict, but you'll nearly always get a BSOD if that's the case.
I'd reformat to remove any doubts about software.
Also, if you are OCing, drop to stock for a while to see what happens.