As the local Fire AHJ plan checker, I always red-line panels in residential closets. I don't ask whether they'll have clothes, I just require that the panel be moved. If they question it, my response is: "The next time a city employee sees this after final is when the fire engine crew is here at 3:00 A.M., so let's design it in a safe manner for the resident 20 years from now who doesn't know it's not for clothes."
Our Senior Electrical Inspector is on the same page that I am.
