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In counsel's view, the applicable test is that set forth in Craven v. ... Gregory (hereinafter Craven v. White) (1988), 62 TC 151 (H.L.). As a result, for there to be a series, there must be a direct connection or link between transactions such that all the transactions in the series must have been preordained, in effect forming a single composite transaction. ... Accordingly, it is his contention that SRMP's transactions would be part of the series, and whether or not they were avoidance transactions is irrelevant. [156]        In any event, counsel for the Respondent contended, should the Court apply the Craven v. ...

One of these residential properties is situated on Craven Road in Toronto (the Craven Road property) and the other is situated on Fourth Street in Mississauga (the Fourth Street property). ... Craven Road property [13] The oral and documentary evidence establishes that the Craven Road property was a basic bungalow when purchased by the appellant for renovation and re-sale. ... Note that new extensions to the existing building are not to be included in determining degree of renovation. [35] As for the Craven Road property, I have to say that given the renovations as described above, I cannot conclude that the building in effect was “gutted”. ...

The land at Craven- totalling 10 acres- had flat areas suitable for cultivation. ... In 1993-94, he felt some headway had been made on the Craven farm so he decided to build an equipment shed. ... Once the alfalfa and brome crops were destroyed by flooding, the Craven farm never generated any income. ...

The respondent referred me to a decision of my colleague Bowman in Craven v. ... Craven v. Canada), [1995] 1 C.T.C. 2883 (T.C.C.). I concur in the conclusion he came to therein. ...

Dawson, [1984] A.C. 474 (H.L.) and Craven v. White, [1989] A.C. 459 (H.L.). In Craven v. White, Lord Oliver set out the approach at page 514: As the law currently stands, the essentials emerging from Furniss v. ...

We agree with the majority of the Federal Court of Appeal in OSFC and endorse the test for a series of transactions as adopted by the House of Lords that a series of transactions involves a number of transactions that are 'pre-ordained in order to produce a given result' with 'no practical likelihood that the pre-planned events would not take place in the order ordained': Craven v. ... Inland Revenue Commissioners, [1981] 1 All E.R. 865. [63]     The fuller quote from Craven v. ...

Duke of Westminster, [1936] A.C. 1; Craven v. White, [1989] A.C. 398; Canada v. ... As explained in Trustco, a series of transactions involves transactions that are “‘pre‑ordained in order to produce a given result’ with ‘no practical likelihood that the pre-planned events would not take place in the order ordained’” (para. 25, citing Craven v. ...

Counsel relied heavily upon the english case of Craven v. White, [1987] STC 297 (C.A.), at page 323. ... Counsel argued that Craven v. White, supra, was not a time limitations’ case. ... The Court rejects the Respondent’s position that the case of Craven v. ...

In Craven v. The Queen, 94-2619(IT)I, I stated: The application of the inflexible test in section 118.4 leaves the court no room to apply either common sense or compassion in the interpretation of the disability tax credit provisions of the Income Tax Act-- provisions that require a compassionate commonsense application. ...

In Craven v. The Queen, 94-2619(IT)I, I stated: The application of the inflexible tests in section 118.4 leaves the court no room to apply either common sense or compassion in the interpretation of the disability tax credit provisions of the Income Tax Act- provisions that require a compassionate and common sense application. ...