The University of Northern California pays no taxes on the dividend income and capital gains received on its various endowment funds. Over the years, it has steadily bought the stock of IVM Corporation for its alumni fellowship fund. The alumni campaign is such that the bulk of alumni giving occurs in the months of June and December. Coincidentally, IVM pays a semiannual dividend in these months. In the past, the university has not paid attention to whether it bought the stock before or after the ex-dividend dates of June 10 and December