It depends on what the fan is being used for intake or exhaust. You wouldn't want an intake fan mounted on the rear when you need an exhaust fan there to draw heated out along with cooling the transformer. On the inside you would position the fan to draw warm heated air in to cool components inside off while forcing that air through the supply for cooling there. Some supplies with smaller fans will see two intake fans on the inside for this.
If you have a weird case like the antec p180b, you dont want a bottem fan, as the PSU is located on the bottom of the case. Besides that, normally fans are positioned in places for a reason.
On a case like the Antec model named there the supply would probably have a side fan or fans facing the front of the case rather then a bottom if at all. For a look at that model case go to http://www.newegg.com/Product/Product.asp?Item=N82E16811129017
It deoends mainly on the type and style of the supply. The fans are there either to draw air in or to expel heated air out. Some have a single 120mm fan at the bottom and simply have an air vent on the outer rear while others will see a smaller 60-80mm fan there for exhaust.