It most certainly depends on power draw. For argument sake any receivers should be 4 ohm stable if you only draw milliamps from them. That is, you have the volume turned right down to say -50 or lower. Even if you draw some real power, say 2 watts, a $500 receiver will still be 4 or even 2ohms stable. By the way, in a HT set up, most people use a powered subwoofer to take care of LFE so the receiver does not have to deal with those low frequency power draws.
You asked a theorectical question so I hope you don't mind a theorectical answer.