Section 1552. Allocation

Where the taxable insurance contract covers risks
  located or resident both within and without this state,  the  amount  of
  premiums  allocable to risks resident or located within this state shall
  be determined pursuant to rules and regulations of the  commissioner  of
  taxation  and  finance.  In promulgating such rules and regulations, the
  commissioner of taxation and finance shall give due consideration to the
  rules and regulations promulgated by  the  superintendent  of  insurance
  pursuant  to  subsection (b) of section nine thousand one hundred two of
  the insurance law.