When Gotti made the "brilliant" move of stripping Anthony Scotto of his Captain rank in favor of a nobody, it was because Anthony Scotto had never pulled the trigger, and thus was ineligible to even be made.
As far as I know, you don't necessarily have to kill somebody to get made. Moneymakers are more important than killers. It's always been that way since the beginning of the Five Families.
"It was between the brothers Kay -- I had nothing to do with it."
