Let's try another approach to show a recept servicing the area behind the stove ...
Assume we place a recept behind the stove and another 12' away. The recept "behind the stove" is inaccessible for all practical purposes. The recept "12' away" needs to service devices 9-11' away from it. Not quite in the spirit of the code.
The argument for a recept servicing the area behind the stove seems foolish.
