One might have been capable of being a paper MCSE back in the days of NT4, but in the W2K world it's just not a runner - there's 7 exams (4 core plus three electives) and they're bloody hard for a total of 24 hours of exams.
I did thirty days of training and that doesn't including the days and days I spend swotting for the exams themselves.
Paper MCSE? A term thrown about by those who don't know what the current MCSE qualification entails, methinks :-)
Often, I think, the term arises in reference to MCPs - i.e. individuals who have passed ONE exam.