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NEC? I don't see any electrical work in this picture. It's horrible hackery, but it's not clear to me that there's necessarily any code violation. If the wall's not load-bearing, removing the structural support for the door's header may not violate any code. I'd guess that the cabinets were there before, and someone just sawzalled away part of the wall to widen the door. If the wall is load-bearing, then removing the support for the header doesn't seem right.
 

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Looks like someone wanted a wider refrigerator and was hell bent on getting it in that spot before the end of the day. Not a candidate for a House Beautiful article but it does stand as a testament to what thinking outside the box and maybe a little alcohol can achieve.
 
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