IMHO, 'jpegPhoto' is a better choice, because it clearly specifies the intended image format.
Technically, the 'photo' attribute as defined in RFC1274 is encoded in a format that by now is certainly less common than jpeg. See RFCs 1274 and 2798 for details.
Of course, if you will be using a certain app that absolutely requires one or the other, then your choice is easy.
From RFC2798:
...
( 0.9.2342.19200300.100.1.60
NAME 'jpegPhoto'
DESC 'a JPEG image'
SYNTAX 1.3.6.1.4.1.1466.115.121.1.28 )
...
( 0.9.2342.19200300.100.1.7
NAME 'photo' )
Note: Photo attribute values are encoded in G3 fax format with an
ASN.1 wrapper. Please refer to RFC 1274 section 9.3.7 for
detailed syntax information for this attribute.
...