I would say there are a hundred sub categories for preferences. I think you should write the stories that you like and you will find automatically find the others who enjoy your same preferences reading your stories. I have found it is really hard for me to write stories that I don't like the subject of. It is just hard to do. For me pretty much MILF's in any kind of amateur combat, especially wives in catfights. In general I would say clothed as I don't think most wives strip down before fighting. That is male fantasy. However, if there is a good logical or plausible reason for the women being naked, that works too (ie, catfight in the showers, nudist colony, torn clothing, caught in the act, etc.)