What is the general rule for planting near a foundation?

I know you don't want to plant anything that will become huge next to a foundation, but how is it affected by pruning. For example, what is the largest apple rootstock you could do near a foundation if you kept it on an espalier?

I'm looking for general guidelines, as we have an area that is close to the foundation in our garage, and I'm hoping to plant some apple trees on an espalier there. And I have a new tree I just made at the grafting class and would love to put it in there. It's an M9 rootstock.