Taxpayer, a life insurance agent, after the termination of Taxpayers agency contracts and services as agent, made assignments in 2015 and 2016 of renewal commissions to become payable to Taxpayer for services which had been rendered in writing policies of insurance under two of Taxpayers agency contracts. The assignments were to Taxpayers children. Taxpayer did not include this amount in gross income for either year.

Who is taxable on this income?

*Taxpayer or

*Children