The Supreme Court of the United States has held that separate convictions for conspiracy to commit and completion of a federal gambling offense are not subject to the presumption of merger created by Wharton's Rule because Congress intended to retain each offense as an independent weapon in combating organized crime.
Iannelli v. United States, 420 U.S. 770 (1975).
Criminal Law - Conspiracy - Wharton's Rule - Organized Crime Control Act of 1970,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol14/iss3/10