I've seen all types, mainly bottom flat (means the pipe supports are all at the same level and easy draining), and concentric (gas and liquid, especially when very close to the valve, but only occasionally top flat.
It's more about your piping layout and where your vents and drains are than anything else and only you know that.
As pennpiper says, the majority are probably concentric because it looks good and there is no disruption to flow. Either that or bottom flat a few pipe diameters away from the valve so you don't get any strange vortices or anything.
My motto: Learn something new every day
Also: There's usually a good reason why everyone does it that way