Subject: Re: 34 Felony Counts
One could say, "Payment for legal services" (which technically, this was).
Except it wasn't. Cohen wasn't being paid for legal services - he was being reimbursed for the payments he made to Daniels, and to cover the income tax impacts that resulted from this particular effort to conceal the true nature of the payments in Trump's business record.
If Trump (or Cohen, for that matter) could prove that those payments were in fact compensation for legal services provided by Cohen to Trump, neither would have been in criminal jeopardy. Unfortunately for both, though, that wasn't true.