Ownership Submission
FORM 3
 UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

INITIAL STATEMENT OF 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 *
  Adkins Rodney C
 2. Date of Event Requiring Statement (Month/Day/Year)
05/18/2007		 3. Issuer Name and Ticker or Trading Symbol
INTERNATIONAL BUSINESS MACHINES CORP [IBM]
(Last)
(First)
(Middle)
IBM CORPORATION, 294 ROUTE 100		 4. Relationship of Reporting Person(s) to Issuer
(Check all applicable)
_____ Director _____ 10% Owner
__X__ Officer (give title below) _____ Other (specify below)
Senior Vice President
 5. If Amendment, Date Original Filed(Month/Day/Year)
(Street)

SOMERS, NY 10589		 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 Beneficially Owned
1.Title of Security
(Instr. 4)		 2. Amount of Securities Beneficially Owned
(Instr. 4)		 3. Ownership Form: Direct (D) or Indirect (I)
(Instr. 5)		 4. Nature of Indirect Beneficial Ownership
(Instr. 5)
Common Stock 171.558
D
 

Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly. SEC 1473 (7-02)
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Table II - Derivative Securities Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security
(Instr. 4)		 2. Date Exercisable and Expiration Date
(Month/Day/Year)		 3. Title and Amount of Securities Underlying Derivative Security
(Instr. 4)		 4. Conversion or Exercise Price of Derivative Security 5. Ownership Form of Derivative Security: Direct (D) or Indirect (I)
(Instr. 5)		 6. Nature of Indirect Beneficial Ownership
(Instr. 5)
Date Exercisable Expiration Date Title Amount or Number of Shares
Emp. Stock Option (right to buy) 02/24/2002(1) 02/23/2008 Common Stock 489 $ 51.155 D  
Emp. Stock Option (right to buy) 02/23/2003(1) 02/22/2009 Common Stock 562 $ 88.955 D  
Emp. Stock Option (right to buy) 02/23/2003(1) 02/22/2009 Common Stock 8,438 $ 88.955 D  
Emp. Stock Option (right to buy) 02/29/2004(1) 02/28/2010 Common Stock 726 $ 103.25 D  
Emp. Stock Option (right to buy) 02/29/2004(1) 02/28/2010 Common Stock 8,274 $ 103.25 D  
Emp. Stock Option (right to buy) 02/27/2005(1) 02/26/2011 Common Stock 955 $ 104.71 D  
Emp. Stock Option (right to buy) 02/27/2005(1) 02/26/2011 Common Stock 19,145 $ 104.71 D  
Emp. Stock Option (right to buy) 02/26/2006(1) 02/25/2012 Common Stock 25,029 $ 97.59 D  
Emp. Stock Option (right to buy) 02/25/2007(1) 02/24/2013 Common Stock 17,260 $ 78.13 D  
Emp. Stock Option (right to buy) 02/24/2007(2) 02/23/2014 Common Stock 24,746 $ 105.96 D  
Emp. Stock Option (right to buy) 03/08/2008(3) 03/07/2015 Common Stock 1,883 $ 92.12 D  
Emp. Stock Option (right to buy) 03/08/2007(2) 03/07/2015 Common Stock 21,400 $ 101.33 D  
Emp. Stock Option (right to buy) 05/08/2009(3) 05/07/2016 Common Stock 3,689 $ 82.76 D  
Rst. Stock Unit   (4)   (4) Common Stock 5,000 $ 0 D  
Rst. Stock Unit   (5)   (5) Common Stock 11,628 $ 0 D  
Rst. Stock Unit   (6)   (6) Common Stock 5,313 $ 0 D  
Rst. Stock Unit   (7)   (7) Common Stock 4,737 $ 0 D  
Phantom Stock Unit   (8)   (8) Common Stock 8,645 $ 0 D  
Rst. Stock Unit   (9)   (9) Common Stock 6,010 $ 0 D  

Reporting Owners

Reporting Owner Name / Address Relationships
Director 10% Owner Officer Other
Adkins Rodney C
IBM CORPORATION
294 ROUTE 100
SOMERS, NY 10589		       Senior Vice President  

Signatures

D. Cummins for Rodney C. Adkins by power-of-attorney 05/24/2007
**Signature of Reporting Person Date

Explanation of Responses:

* If the form is filed by more than one reporting person, see Instruction 5(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) This grant vested in four equal annual installments; the last installment vested on the date shown above.
(2) This grant vests in four equal annual installments; the most recent vesting occurred on the date shown above.
(3) This grant vests in its entirety on the date shown above.
(4) These units are payable in cash or the company's common stock upon lapse of the restrictions on November 5, 2009.
(5) These units are payable in cash or the company's common stock upon lapse of the restrictions on December 6, 2009.
(6) Upon lapse of the restrictions, these units are payable in cash or the company's common stock. The restrictions lapse for 2,656 of these units on May 8, 2008, and for 2,657 of these units on May 8, 2010.
(7) Upon lapse of the restrictions, these units are payable in cash or the company's common stock. The restrictions lapse for 2,368 of these units on May 8, 2009, and for 2,369 of these units on May 8, 2011.
(8) Phantom stock units acquired under the IBM Executive Deferred Compensation Plan convert to the cash value of the company's common stock on a one-for-one basis, and distribution is deferred until separation from the company.
(9) These units have been deferred and are payable in the company's common stock upon lapse of restriction after retirement.

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