Problem: Charles Darwin entered into an agreement with his employer, Kingston University, which provides that any patents produced from Charles research would belong to the University and that the University would pay Charles 50 percent of any royalty income derived from any such patents. When Charles entered into the employment agreement with Kingston University, Charles also executed a written assignment to his two children, assigning to them any royalty income that should become due to him under his employment agreement. Charles's work produced a patent that generated $50,000 of royalty income in the current year, and pursuant to the agreement $25,000 was paid by Kingston University to Charles's children. Who is taxable on the patent income?