Hi Jerry,
I inspected a home today where the "investor" remodeled the the kitchen and changed the layout. No permit found.
He added a tall cabinet where originally there were wall and base cabinets. He enclosed the lead (GFCI) receptacle for 1 of the small appliance circuits in the cabinet (through a cut hole of course) and has placed a counter top microwave on a shelf in front of it. The range is gas and he removed the original "over the range microwave" and installed a fancy hood above the range.
So now the receptacle is not readily accessible but the remaining receptacle spacing is ok. I can't find anything in the NEC that would specifically prohibit this.
While its not a big deal can you make a GFCI receptacle "not readily accessible?
David McCabe