Can a trial court use the Cost approach to determine the presumptive value of periodic payments made through an annuity?

We conclude, therefore, nothing in section 6146 prevents the trial court from using the Cost approach to determine the presumptive value of periodic payments made through an annuity. We wish to make it clear, however, the plaintiff's attorney should be given the opportunity to show in a given case [40 Cal.App.4th 1454] that the cost of the annuity does not reflect the reasonable present cash value of the periodic payments. ¹⁴ (Cf. Wyatt v. United States, supra, 783 F.2d at pp. 47, 50.) While use of the Cost approach as a presumptive guidepost will not eliminate the potential for controversy over the value of periodic payments it will, we believe, produce the least amount of controversy because it is objective, simple and inexpensive to apply. (Schneider v. Kaiser Foundation Hospitals, supra, 215 Cal.App.3d at p. 1319, 264 Cal.Rptr. 227.) ¹⁵