We have a project coming up where we will be building a whole backend CMS system that will power our entire extranet and intranet with one package. The question I have been
Assuming you are in a windows environment there is no great reason to use the file system. You may want to be careful how you store the images in the tables to avoid unwanted page splits, but that's a performance tweak, not a huge issue.
Downsides to filesystem
-Not automatically replicated
-May complicate your replication by having different physical locations for every instance
-Slow with very large numbers of files
Upside to the filesystem
-If you're storing a few very large files, it will perform a bit better.