I'd use a liter in an 8x10" tray for 4 sheets or fewer. More definitely makes things easier. I generally keep the stack near the edge closest to me and pull the sheet entirely out before lifting it.
With smaller trays, I found there was more of a risk of corners scratching the sheet on the bottom of the stack as I pulled it up.
The film also makes a difference. I found that when I started using Efke and Classic/Forte, which are much less scratch resistant than Kodak or Ilford, I really had to refine my tray development technique. Still, I'm getting very light abrasions on my 5x7" Classic 400 negs--not enough to be visible in a contact print, but if I were enlarging, it could be a problem. Meanwhile, I've picked up a dozen 5x7" hangers and am awaiting the delivery of some 5x7" tanks. I'll probably still use trays for fewer than 6 sheets, but the tankline looks like a good method for larger batches.