I don't agree with Seal Brown, as there is no tan around the flanks, elbows or muzzle/eye areas, could be wrong but I am under the understanding that Seal Browns have to have at least some shading in those areas, other wise they are Black or Dk Bays.
There appears to be brown on her flanks or belly, and her legs. I agree that there is none (at least in the pic) of any on her muzzle; but I would still call her a seal brown.
Dark liver chestnuts have often been called brown for this reason. Look at the horse you are talking about again, and this time, look at the lower leg. It gets definitely lighter, and more towards a chestnut colour. That is one of the easiest ways to tell a liver chestnut from a brown or sun fading black
I love reading these posts about color - there is so much confusion about it. I've learned a good deal from them and I'm impressed about how much some of the members know about genetics. I may be old and have been around horses pretty much my whole life but I love learning new things - color, or the nuances of it, was just not something that was really thought about.
LOL, I know he looks it, but he is definitely a liver chestnut. We used to have one that was colored almost identical to him. Unfortunately, I have no good pictures of old Judge. Reata Ranch Home of World Class Show Horses