What are the legal consequences of a judicial anti-avoidance measure?

[53] In England, the courts have created judicial anti-avoidance measures whereby they ignore the legal effects of otherwise valid transactions in certain circumstances. The Craven v. White factors are a common law code for determining not only whether a series exists, but also when the legal effect of an intermediate transaction in the series, which has no other purpose than tax avoidance and which is not intended to have any independent life, may be ignored.