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  5. 853 P.2d 770 (1993)
 

IBM v. OKLAHOMA TAX COM'N

No. 74715.

853 P.2d 770 (1993)

INTERNATIONAL BUSINESS MACHINES CORPORATION, Appellant, v. OKLAHOMA TAX COMMISSION, Appellee.

Supreme Court of Oklahoma.

Rehearing Denied June 15, 1993.

Attorney(s) appearing for the Case

L.E. Stringer, Jean A. McDonald, Roger A. Strong, Oklahoma City, for appellant.

Joe Mark Elkouri, Christy J. Caesar, Linda Ruschenberg, Oklahoma City, for appellee.

HARGRAVE, Justice.

The question before us is whether certain sales made by International Business Machines ("IBM") are subject to municipal sales tax in Oklahoma. The administrative law judge, based on stipulated facts, found that transfer of possession occurred in Oklahoma and that the transfers were subject to the sales tax. The Oklahoma Tax Commission adopted the findings, conclusions and recommendations of the administrative...

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