Ownership Submission
FORM 4
Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP OF SECURITIES

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934, Section 17(a) of the Public Utility Holding Company Act of 1935 or Section 30(h) of the Investment Company Act of 1940
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(Print or Type Responses)
1. Name and Address of Reporting Person *
SANFORD LINDA S
   2. Issuer Name and Ticker or Trading Symbol
INTERNATIONAL BUSINESS MACHINES CORP [IBM] 		5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)
_____ Director _____ 10% Owner
__X__ Officer (give title below) _____ Other (specify below)
Senior Vice President
(Last)
(First)
(Middle)
IBM CORPORATION, 294 ROUTE 100		 3. Date of Earliest Transaction (Month/Day/Year)
05/08/2007
(Street)

SOMERS, NY 10589		 4. If Amendment, Date Original Filed(Month/Day/Year)
 6. Individual or Joint/Group Filing(Check Applicable Line)
_X_ Form filed by One Reporting Person
___ Form filed by More than One Reporting Person
(City)
(State)
(Zip)
Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1.Title of Security
(Instr. 3)		 2. Transaction Date (Month/Day/Year) 2A. Deemed Execution Date, if any (Month/Day/Year) 3. Transaction Code
(Instr. 8)		 4. Securities Acquired (A) or Disposed of (D)
(Instr. 3, 4 and 5)		 5. Amount of Securities Beneficially Owned Following Reported Transaction(s)
(Instr. 3 and 4)		 6. Ownership Form: Direct (D) or Indirect (I)
(Instr. 4)		 7. Nature of Indirect Beneficial Ownership
(Instr. 4)
Code V Amount (A) or (D) Price
Common Stock 05/08/2007   M   2,875 A $ 0 5,101.8159 D  
Common Stock 05/08/2007   F   1,260 D $ 102.8 3,841.8159 D  
Common Stock               2,091.1734 I (1) son

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Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned
(e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security
(Instr. 3)		 2. Conversion or Exercise Price of Derivative Security 3. Transaction Date (Month/Day/Year) 3A. Deemed Execution Date, if any (Month/Day/Year) 4. Transaction Code
(Instr. 8)		 5. Number of Derivative Securities Acquired (A) or Disposed of (D)
(Instr. 3, 4, and 5)		 6. Date Exercisable and Expiration Date
(Month/Day/Year)		 7. Title and Amount of Underlying Securities
(Instr. 3 and 4)		 8. Price of Derivative Security
(Instr. 5)		 9. Number of Derivative Securities Beneficially Owned Following Reported Transaction(s)
(Instr. 4)		 10. Ownership Form of Derivative Security: Direct (D) or Indirect (I)
(Instr. 4)		 11. Nature of Indirect Beneficial Ownership
(Instr. 4)
Code V (A) (D) Date Exercisable Expiration Date Title Amount or Number of Shares
Rst. Stock Unit $ 0 (2) 05/08/2007   A(2)   7,579     (2)   (2) Common Stock 7,579 $ 0 7,579 D  
Rst. Stock Unit $ 0 (3) 05/08/2007   M(4)     2,875   (3)   (3) Common Stock 2,875 $ 0 5,750 D  
Phantom Stock Unit $ 0 (5) 05/08/2007   A(6)   18     (7)   (7) Common Stock 18 $ 0 4,515 D  

Reporting Owners

Reporting Owner Name / Address Relationships
 Director  10% Owner  Officer  Other
SANFORD LINDA S
IBM CORPORATION
294 ROUTE 100
SOMERS, NY 10589		       Senior Vice President  

Signatures

 D. Cummins for L. S. Sanford by power-of-attorney   05/09/2007
**Signature of Reporting Person Date

Explanation of Responses:

* If the form is filed by more than one reporting person, see Instruction 4(b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
(1) The reporting person disclaims beneficial ownership of the securities, and this report shall not be deemed an admission that the reporting person is the beneficial owner of such securities for purposes of Section 16 or for any other purpose.
(2) Upon lapse of the restrictions, these units are payable in cash or the company's common stock. The restrictions lapse for 2,526 of these units on 05/08/2008, for 2,526 of these units on 05/08/2009, and for the remaining 2,527 of these units on 05/08/2010.
(3) These units were payable in cash or the company's common stock upon the lapse of the restrictions on the transaction date shown.
(4) Release of restricted stock units.
(5) Phantom stock units convert to the cash value of the company's common stock on a one-for-one basis.
(6) Acquisition of phantom stock units under the IBM Executive Deferred Compensation Plan.
(7) Distribution of phantom stock units under the IBM Executive Deferred Compensation Plan is deferred until separation from the company.

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