It seems clear that the master found it necessary to consider the doctrine of estoppel in this case because of the principle of law which holds that a deed in which the name of the grantee has not been inserted is inoperative as a conveyance so long as the blank remains unfilled. Simpson v. Hirshberg, 1947, 159 Fla. 25, 30 So.2d 912; Annotation, 1947, 175 A.L.R. 1294. This principle of law applies to this case and we therefore hold that the deed in blank from the Conways to Miami Gardens is inoperative as a conveyance of the lands in question in this suit. Having so decided it is readily apparent that the doctrine of merger does not operate here since such doctrine operates only when "* * * a greater estate and a less coincide, and meet in one and the same person, in one and the same right, without any intermediate estate."

We have previously held that the status of title to real estate on the first day of January of any tax year determines the person in whose name such real estate shall be assessed and determines the right to the homestead tax exemption. Simpson v. Hirshberg, 1947, 159 Fla. 25, 30 So.2d 912; Sec. 192.04, Florida Statutes, 1953, F.S.A. Therefore the plaintiffs' rights must be determined by the status of their title or interest in the lot as of January 1, 1954. It is obvious that plaintiffs were not the owners of the legal title to the lot on January 1, 1954. Their right to the tax exemption, if any right they have, must be based on a claim that they held the beneficial title to said lands as of January 1.

The complaint states a cause of action. Belcher Center LLC correctly asserts that a deed from the owner to a nonexistent entity is a nullity, see Daniels v. Berry, 513 So.2d 250, 251 (Fla. 5th DCA 1987), and a deed not containing the names of the grantees is void, see Simpson v. Hirshberg, 159 Fla. 25, 30 So.2d 912, 912 (1947). We, therefore, must reverse the dismissal with prejudice for further proceedings to consider the application of the affirmative defense of the doctrine of estoppel by deed or equitable estoppel.

The deed in question names Sara F. Francis, rather than the decedent, as the grantor of the decedent's residence and does not contain the name of the grantee; the portion of the deed reserved for the name of the grantee is left entirely blank. It is settled in Florida that a deed which does not contain the name of the grantee, as here, is void and inoperative as a conveyance. Miami Gardens, Inc. v. Conway, 102 So.2d 622, 625 (Fla. 1958); Simpson v. Hirshberg, 159 Fla. 25, 29-30, 30 So.2d 912, 914 (1947). Beyond that, the deed further contains a cryptic handwritten provision: "Two have + hold for Ricky Stewart as long as they Both shall Live, as they keep up the Property and Taxes[.

The opinion concluded that the person would not be entitled to the exemption for that year because his status as being subject to taxation is determined as of the date of assessment, January 1, of each year. See Simpson v. Hirshberg, 30 So.2d 912 (Fla. 1947); Gautier v. Lapof, 91 So.2d 324 (Fla. 1956); and Jacksonville Expressway Authority v. Milford, 115 So.2d 778 (1 D.C.A. Fla., 1959). In view of the foregoing, I conclude that the provisions of s. 3 of ch. 78-269, Laws of Florida, are not sufficient authority to reimburse local governments for revenues lost during the 1978 tax year due to the provisions of s. 193.511, F. S.