Starting with Windows 2000, MS decided to restrict the internal formatting routine, so you can only format partitions up to 32GB in FAT32. For larger partitions, you need a 3rd party software. Some HDD manufacturers offer tools to do that. These only work with external HDDs from this manufacturer.
H2format (available from here: http://www.heise.de/ct/ftp/ctsi.shtml) is a command line tool that works manufacturer independent.
Only for partitions up to 32GB.