1. (a) A telephone or telegraph corporation which is required to allocate items of gross operating revenues from interstate and foreign transmission services shall allocate such revenues by totaling, worldwide, all items of gross operating revenues from interstate and foreign transmission services to which the allocation by accounting method cannot be feasibly applied, and multiplying such worldwide total by an allocation percentage computed on the basis of a formula consisting of two factors. The two factors, expressed as percentage, are:

   1. (1) the revenue-producing circuit miles factor (see section 41.4 of this Part - Computation of the revenue-producing circuit miles factor); and
   2. (2) the property factor (see section 41.5 of this Part - Computation of the property factor).

2. (b) The allocation percentage is computed as follows:

   1. (1) for the taxable year 1986, by multiplying the taxpayer's property factor by 65 percent and the taxpayer's revenue-producing circuit miles factor by 35 percent and totaling the resulting products;
   2. (2) for the taxable year 1987, by multiplying the taxpayer's property factor by 72.5 percent and the taxpayer's revenue-producing circuit miles factor by 27.5 percent and totaling the resulting products;
   3. (3) for the taxable year 1988, by multiplying the taxpayer's property factor by 82.5 percent and the taxpayer's revenue-producing circuit miles factor by 17.5 percent and totaling the resulting products;
   4. (4) for the taxable year 1989, by multiplying the taxpayer's property factor by 92.5 percent and the taxpayer's revenue-producing circuit miles factor by 7.5 percent and totaling the resulting products; and
   5. (5) for the taxable year 1990, and for any subsequent taxable year, such allocation percentage of the taxpayer is the taxpayer's property factor.

Tax Law, § 184.4(d)