A North Carolina photographer transferred commercial photographs to clients both over the Internet and on paper. The taxpayer was not subject to collection of sales tax on the photographs delivered via the internet because the items transferred were not in the form of tangible personal property. The taxpayer was subject to collection of sales tax on the photographs that had been delivered to the client on photographic paper which is considered tangible personal property. (North Carolina Department of Revenue, Secretary of Revenue Docket No. 2003-171, Decided August 29, 2003)