Because the head is probably warped. You ALWAYS check the head and block sealing surfaces for warpage when replacing a head gasket. I had 2 heads for a V8 completely stripped, cleaned, rebuilt with the valves reground, and milled for $500. Just milling an otherwise good head shouldn't add more than a couple hundred to a head gasket replacement job.
If you're up for it, I'd pull the plugs and see what color they are. If any are bright white then I'd ask the shop if they checked the head/block for warpage, cracks, and pressure tested the cooling system. Unless the shop that did the work can prove they checked the block/head for warpage, (did they document it on the work-order/invoice?) I'd make 'em redo it right.
EDIT: Hey Don, just curious but why was the head gasket replaced/how did it fail originally? Was there smoke, water in the oil, or loss of compression? Did the engine overheat?
The reason that the Head Gasket was replaced is due to the overheating and loss of radiator fluid with no visible external leaks.
The Radiator, Thermostat, Water Pump and a few hoses were already replaced prior to the head gasket.
The head gasket was replaced less than 5 months ago. I just had a mechanic check for any external problems the other day and he could not find any.
So I brought it back into the shop that replaced the head gasket today.
Originally, this shop did a good job on the head gasket replacement, see repair below. click to Enlarge
I made a PDF incase you cannot read the jpg.

It does appear from the invoice that new bolts were used and the head was re-surfaced!
Also to aid in finding the latest problem I wrote down this account of what happened yesterday.
To aid in diagnosing the current overheating problem in my 1999 Subaru Wagon. Here is an account of what happened.
As you know, back in late January I brought the car in for a new head gasket. It already had a new radiator and there were no external leaks in the coolant system.
So the job went well and I did bring it back to have it checked a few days later to make sure the temp gauge fluctuation was ok.
We also kept an eye on the water in the coolant system adding some whenever needed. It seemed lately we had to add more and more. Finally on my trip up to Lancaster NH it went crazy. The temp guage was fine on the way up and we did closely monitor this gauge. Then we came back to Rt 93 exit 32 and had some supper. We got back on the highway and soon noticed the temp gauge pegged at HOT! So we took an exit and put more than 2 gallons of water in the radiator and still no visible signs of any external leaks. We drove around and the temp went back up to HOT. Luckily I found one of the best garages in the White Mountains! (Campton Mobil LLC 254 route 49 Campton, NH 03223) I purchased a bottle of Bar’s Leaks – Radiator Stop Leak that Subaru recommends and put it in the coolant system. I drove down an exit on the highway and back and the temp gauge pegged at HOT again. Since it was getting late, we left the car for George to look at in the morning. Getting stuck on Rt. 93 at night was not a very good option! George has many years of experience and in fact he has changed a Subaru Outback head gasket in the past! So he added antifreeze and a quart of oil and drove the car and checked for any leaks. He found no external leaks. So we picked up the car that afternoon and attempted the approx 90 mile drive home from Rt 93 exit 28 to Rt 93 Exit 1. After only one exit or so the temp guage started climbing above half way and then go back to half way. A couple of times it went to just under HOT and back down. Then when we hit the Hooksett tolls it went to HOT and stayed there. We pulled over and added a gallon of water after the car cooled down and drove it back to Salem. This temp gauge again started fluctuating going toward Salem and when we took Exit 1 after about only 40 min on the highway, it went to HOT and stayed there as we just barely got it home! After the car cooled down for 4 or 5 hours it needed another gallon of water!
I believe the Bar’s Leaks Radiator Stop Leak helped us get the car home safely but did not fix the problem and something needs to be fixed to drive without overheating.