it depends, now this is the police answer, which I know for sure;
for police, the brown was rural, the black was municipal...
many collectors feel the brown was for air force and the black was army. I believe there is a truth in that, as the army required all holsters to be dyed black in the mid 1920's. but I have heard and seen brown army holsters as well as black. Before this time, many holsters were brown, so you will find them black dyed on the front (fading many times) and definately brown on the rear.
Ed
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