Good point Leland, I guess I'd still allow it as long as the receptacle was less than 12" from the counter top surface. Some of these custom installs are judgment calls and as long as they can give me code or equivalency I'm happy.
If I have a table, it's just a table. If I have a pine hutch, it's just a hutch. But if I bolt the hutch to the wall to prevent it from tipping over, is it suddenly cabinetry and counter? If I bolt the table to the floor because the base is a bit undersized and unstable, have I now just created an island?
Steve, I would say that making the furniture permanent does mean the rules now apply.
The hutch example is a bit of a non-issue, as you need more than 12" of depth to that open area for the counter rules to apply. I've seen many hutches that lack that depth.
Indeed, here's an example of a kitchen counter that -over a 14 ft. run - required only one receptacle:
Here's a pic of another peninsula, where you can see the receptacle on the adjoining wall. As I read the code, you would need another receptacle in the 'toe kick' area of the bar, approximately where I placed the white "X":