Really just depends. Memory is taken up by the operating system, that is not shown in your total memory in itunes. My 32 shows me having just under 30GB of memory from a fresh restore. Much like hard drives, it isn't on the dot with what is advertised.
When you change firmware, do you click 'Update' or do you click 'Restore'?
You should be clicking 'Restore' and start fresh every time because if you don't, you'll lose a little space (about 500mb I believe) each time you 'Update'.