A management contract requiring fees to be paid between a professional corporation of physicians and a partnership that handled all of the administrative operations of the clinic were not subject to Virginia sales and use tax even though some tangible personal property was provided by the management company. It was determined that the true essence of the management contract was to gain the expertise of the management partnership as well as nontaxable professional services. (Ruling of Commissioner, Virginia Department of Taxation, P.D. 02-129, October 6, 2002)