Greg:
The debate had a loud difference of opinions. I'll say by code, as it is within the cabinet, GFI is not a requirement, but a choice by design.
The 'pro GFI' side was argued on safety, but the NEC does not prohibit stupidity, on the part of the end user.
As I mentioned above the common install is single receptacles for the 'fixed' appliances, with an occasional 'split' 15/20 amp duplex. (I omitted 15 in my above post) I'm refering to DWs, GDs, microwaves (in place), compactors, wine coolers, warmer drawers, etc.
