General Discussion - Traditional Character for lǐ ： 裡 or 裏 ?

I've recently come across a variant [ 裏 ] of the traditional character 裡 (lǐ, inside).  I'm used to seeing 裡，so this variant threw me off.

I've learned that they both have the same radical and have the same total strokes:

裡   衣衤 + 7    13 strokes

裏   衣衤 + 7    13 strokes

Does anyone have any insight into why one would be used instead of the other?

Much thanks!