no more than 20% of normal business rates on the buildings they use and occupy. The GMC received confirmation of 80% business rates relief effective from April 1995. the accounts submitted by the GMC to the Charity Commission showed an income of £97 million, spending of £101m with reserves of £68m. Shipman inquiry The GMC was most heavily criticised by Dame Janet Smith as part of her inquiry into the issues arising from the case of Dr Harold Shipman. "Expediency," says Dame Janet, "replaced principle." Dame Janet maintained that the GMC failed to deal properly with Fitness to Practise (FTP) cases, particularly involving established and respected doctors. In response to the Shipman report, Sir Liam Donaldson, the then Chief Medical Officer, published a report titled Good doctors, safer patients, which appeared in 2006. Donaldson echoed concerns about GMC FTP procedures and other functions of the Council. In his view, complaints were dealt with in a haphazard manner, the GMC caused distress to doctors over trivial complaints while tolerating poor practice in other cases. He accused the Council of being "secretive, tolerant of sub-standard practice and dominated by the professional interest, rather than that of the patient". Former President of the General Medical Council, Sir Donald Irvine, called for the current Council to be disbanded and re-formed with new members. Penny Mellor In July 2010 the GMC was severely criticized in an open letter in the British Medical Journal by Professionals Against Child Abuse for the decision to include Penny Mellor on the GMC's Expert Group on Child Protection. According to the letter, Penny Mellor had been convicted and imprisoned for conspiring to abduct a child, and had led protracted hostile campaigns including false allegations against doctors and other professionals involved in child protection cases. She had also campaigned against Sir Roy Meadow and Professor David Southall, who were erased from the medical register by the GMC but subsequently re-instated after court rulings. Penny Mellor subsequently resigned from the Expert Group. John Walker-Smith In March 2012, the High Court of England and Wales overturned a 2010 decision by the GMC to strike pediatric gastroenterologist John Walker-Smith off the medical register for serious professional misconduct. In his ruling, the presiding judge criticized what he said were the GMC's "inadequate and superficial reasoning and, in a number of instances, a wrong conclusion," and stated, "It would be a misfortune if this were to