Ah - but not always! In my other thread I questioned if my black mutang may be brown because now in the winter he was showing brown hairs on his muzzle. And most felt he was black because while there was some brown on the muzzle and lighter brown on his tail his other soft tissue areas really were not lightened. So looks like I have one of each.
Now I do have another question. We know how the smutty/sooty gene can even make palominos look really dark. I wonder what it would do to a brown with it? And have they decided mealy does not work on black-based horses? I know they used to say what is now brown were blacks with mealy.