I've just performed a clean installation of Windows 7 x86 and have audio out of the headphones, albeit unreliably. I simply followed the instructions in the Apple Forums thread concerning this issue:
http://discussions.apple.com/thread.jspa?threadID=2037093&start=465&tstart=0
Here someone posted instructions on how to modify the BootCamp Cirrus audio drivers with a CirrusAudio.10.6.1.zip file that was uploaded here:
http://www.mediafire.com/?mmfmjhtjy0i
Guide to Working Audio Drivers in Windows 7 32 bit(may work in other Windows Operating Systems)
1. Download
http://www.sussex.tec.nj.us/files/CirrusAudio.10.6.1.zip and extract the CirrusAudio.10.6.1 folder. Now find the appropriate driver, in my case it was "CirrusAudioVista32.exe" and use a file extraction tool like WinRar to extract the files from the executable.
2. Find your Snow Leopard DVD, put it into your DVD drive and from windows explorer, explore or open the DVD. Now open the Boot Camp folder and then the Drivers folder. Now find the Cirrus folder, and copy the appropriate driver to your desktop. Again use a file extraction tool like WinRar to extract the files from the executable.
3. Now open the Second CirrusAudioVista32 folder created in Step 2, find the file named "CirrusAPO_x86.dll" and copy this file. Now open the First CirrusAudioVista32 folder created in Step 1 and paste the "CirrusAPO_x86.dll" over the existing (replace) file.
4. Now if you have not uninstalled the previous version of the driver, open the control panel and uninstall the Cirrus Logic, Inc driver and reboot.
5. Once your computer has restarted, open the First CirrusAudioVista32 folder created in Step 1 and double click the DPInst.exe, and your new driver will install.
The original link was dead but I found the .zip file by Googling. I followed the instructions using the Boot Camp drivers provided with the Mac OS X installation DVD.
Headphones are now functioning, but upon restarting the driver sometimes fails to load and needs to be troubleshooted.
Not an ideal solution, but for the time being I'll live with it.
The Windows XP drivers provided at the following site also worked:
http://www.stuffedcow.net/macbook_audio
But the audio quality was poor and only one audio output is recognized (speaker), regardless of whether or not the headphones are inserted.
Here's the modified CirrusAudioVista32.exe file I created using the above procedure. Just remove the .zip extension and replace the file in the BootCamp drivers folder (\Cirrus).