Agreed, and it can vary a lot between locations. For example, here in Oregon everything in the garage must be GFCI except if you have a single outlet (a duplex is two outlets) for a device such as a freezer and that device blocks access to the outlet, or words that that effect. Anything 5.5' above the floor or less gets a TR outlet.
Personally I hate having GFCI outlets sprinkled all over the place and having to hunt them down so I've resorted to $36 GFCI breakers for many of the circuits.