Winemakers have been arguing for many years that there’s special value in wines made from grapes grown in Napa Valley, Russian River Valley and other prized winegrowing regions to justify bottle prices. Wineries could reap a big harvest of tangible income tax savings by amortizing that intangible value of place under Section 197 of the Internal Revenue Code, according to Greg Scott, a prominent wine industry accountant and partner with PricewaterhouseCoopers LLP in San Francisco. “I have contended since the mid ’90s that this worked,” Mr. Scott said, noting that the IRS hasn’t provided public or private clarification since then. “It is great to finally get affirmation.” Last week, the IRS issued a chief counsel memorandum that the “right” to use such an American Viticultural Area name when selling grapes grown there is an amortizable intangible that can be allocated to a vineyard purchase price.