E3801.4 Countertop receptacles. In kitchens and dining rooms of dwelling units, receptacle outlets for counter spacesshall be installed in accordance with Sections E3801.4.1
through E3801.4.5 (see Figure E3801.4).
E3801.4.1Wall counter space. A receptacle outlet shall be installed at each wall counter space 12 inches (305 mm) or
wider. Receptacle outlets shall be installed so that no point along the wall line is more than 24 inches (610 mm), measured
horizontally from a receptacle outlet in that space.
Exception: Receptacle outlets shall not be required on a wall directly behind a range or sink in the installation
described in Figure E3801.4.1.
This is from the 2006 IRC..... you are correct that a GFCI receptacle is not required 24 inches from the sink.... however, no point on the counter top shall a receptacle be more than 24 inches from another receptacle.