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June 27, 2011

事業譲渡が否認される

事実上倒産状態になった会社が、不採算部門を切り離して債務もろとも事業を譲渡する。
逆に、不採算部門を残して、継続可能な事業部門を譲渡する。
どちらにせよ、不採算部門の道連れにされる債権者は、債権を回収できなくなる。
事業譲渡は割と簡単にできるから、債権者保護の手続が履行されるかが残された重要課題になる。
破産会社が、破産申立前にした事業譲渡が詐害行為になるとして、破産管財人が否認権を行使した例がある。(平22.11.30東京地判)
事業譲渡時に支払い不能状態にあれば、優良部門の事業譲渡は即、責任財産の引き当てを減少を意味し、破産しても配当が受けられない。
否認権行使には、債務者の債権者に対する害意が必要である。社長が同じであるとか、度重なる督促にも拘わらず、ある日突然、一部門の事業が新会社の名で看板が上がり、工場や機械の所有名義も変えられている。残された債権者は強制執行するとしても廃物処理に終わるだけである。新しい会社は元からあったものでも、事業譲渡のために作った会社でも構わない。新会社が旧会社と共に連帯保証していれば、廃物処理のおそれはないが、連帯保証、物上保証がないと、困ったことになる。破産管財人が否認権を行使した結果、不動産の名義は破産会社に戻り、その他の財産は特定が難しいから価格賠償せよ、という判決結果になった。
よく似た例を経験した。食肉加工の会社が肉の仕入代金を払わないで事実上倒産した。どうやら同じ住所で設立登記された別会社に事業を譲渡された模様だ。ただし、帳簿を見ることはできないから、従来の取引先に一つ一つ売掛金の処理、買掛金の処理をどうしたか聞いていくしかなかった。この業界は閉鎖的で、他社の情報を滅多に漏らさない。どうやら食肉加工部門を工場設備と共に新会社に移して頬被りするつりらしい。新会社の社長は旧会社の社長の息子。親父は「新会社に事業譲渡した」というと、息子の会社の資産を押さえられるから、「社名を変更しました」とだけ触れ回った。仮に差押えが来ても、その時は資産台帳を見せて、新会社に賃貸して賃料を貰い、全額、県の融資の弁済に充てている(質権を設定している)、他に差し押さえられる資産はない、と言うわけである。
新旧両会社を相手に裁判して和解し、旧会社に未払代金1500万円の存在と分割払いを認めさせ、新会社にもその一部の400万円の支払につき連帯保証させた。ところが400万円の支払が済んだ途端、旧会社は残りの1100万円の支払をしなくなった。新会社もむろん保証の限度を超えたとして払わない。和解したのに、再度、同じ内容で裁判を起こすことになった。今度は単なる売掛金の請求ではなく、最初から全額払うつもりもないのに、取り敢えず訴訟を終結させるために卸売業者である原告を騙して訴訟上和解した、詐欺か詐害行為にあたる、という内容である。(裁判上の和解が詐欺又は詐害行為にあたるという主張も滅多にない。)弁護士も前の裁判の弁護士と同じだから、詐欺とは何だ、と強く抗議される。
2度目の裁判は、総勘定元帳を出させて、事業譲渡の有無を本格的に争うことになった。会社の設立自体は法的に争えないが、むろん親父の言う「改名」にとどまらない。
一口に事業譲渡と言うが、否認する親子を相手に、立証はけっして易しくない。県から受けた巨額融資は、旧会社が新会社から貰う工場の賃料収入で支払続けている。まるっきり、営業活動を停止したわけではない。しかし、食肉加工品の販売代金の振込入金はもうない。何度か銀行預金を差し押さえたが空振りだった。新会社に対する裁判はこうして事業譲渡の否認という壁に突き当たった。旧会社の帳簿を取り寄せようとしても、存在しない、と提出を拒まれた。(帳簿さえ見れれば新会社の総勘定元帳とつきあわせられる。旧会社の売掛金が新会社に引き継がれ、その名で取り立てられているかも分かる。実績のない息子の会社が設立直後から食肉を仕入れ、加工して販売できたか、活発な取引を開始の理由を突き止められる。)実績のない新会社が設立直後から売上をのばすわけがないから、新会社の取引先を調査すると、この業界を仕切っている大物業者が自社の債権を優先弁済することを条件に、加工用食肉を新会社に卸している事実が分かった。のみならず億を超す新たな融資をしていることも分かった。こうして相手を選んで事業は譲渡されていたのだ。もっとも、このような業界の大物が裁判に登場する事はない。
生殺与奪の権を握っているから、間違っても、優先弁済を受けた等と親子に証言させるわけがない。裁判という舞台の裏で、じっと成り行きを見ている。
新会社から取り残された弱小債権者は、詐害行為あるいは詐欺と主張して、勝訴の見込みも定かでない裁判に立ち向かうのである。文書提出命令、調査嘱託なども功を奏さない。
詐害行為には害意が必要である。害意とは特定の債権者の債権を侵害する意図である。客観的に推認されれば足りるが、弱小は全部切り捨てられたかというと、旧会社の帳簿がないため、その辺が分からない。
新会社の総勘定元帳と入金記録を見ながら、取引の発生源と増加の理由を尋問するには記録に登場する数字の由来を探索するしかなかった。守秘義務も盾にされた。裁判所は、新会社が有力取引先の債務を弁済することで、其処との取引を引き継いだことを認め、職権で和解を勧告し、新会社が旧会社の残債務の相当部分を弁済することになった。熾烈な争いで大変だった。
今、東北大震災の影響で、関東以北のゴルフ場の会員権の取引価格相場が下がっている。ゴルフ場自体の売却も予想される。経営に窮してゴルフ事業が譲渡されたら、会員権は償還されないかも知れない。資力の弱い会社は会員権を償還できないというかも知れない。事業譲渡(営業譲渡)が債権者詐害行為となりうるのである。事業譲渡すべてを否認できないから、そのときは当該会員権の預託金の範囲内で価額弁償が認められることになろう。
債権者詐害行為は、債務を弁済しない計画的な行為であることが殆どだから、準備も周到になされる。だから内部情報の入手が大きな意味を持つのである。この問題特有の裁判の難しさが一般に理解されることは、あまりない。巨額の借金を承知の上で免れようとする。美徳ではなく、世の中がすさんできているのではないか、ときどき思う。すさんだ世をまともに生きるフィリップ・マーロウ(「ロング・グッドバイ」レイモンド・チャンドラー村上春樹訳(早川書房))が格好よく見えるのは自分ができない事をしてくれるからだろう。

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