I use
SageTV for my computerized "tivo" needs. IT supports as many tuners as you can throw at it. I have heard of 8 tuners or more in the server. Run out of space, just add another HD to your computer and tell Sage that it can record to it. There are many customizations available for it. Weather modules, IMDB modules(let you acess IMDB from your TV) and even a webserver module where you can add in a new favorite over the internet. You want Intelligent recording like tivo, it'll do that too.
What I like in a computer based PVR is the expandability. Over time, I have added 5 tuners and more HD space as my needs have grown. It can also be set up to be a "whole-house" solution. I also have it set up in a client/server solution where the main server records all the shows and feeds the shows to 2 clients in different rooms. Both clients can watch different "live" shows at the same time or watch previously recorded shows. My friends with multiple Tivo's have to keep track of what favorites are saved on which tivo.
I also have my DVD's ripped into XVID's and that is stored on a networked drive that can be accessed by the server and clients.
As for hardware specifics, if you get a harware-based MPEG2 encoding card, the CPU usage is very low and can be run on something less like a PIII 833mhz.
I don't recommend the cheaper software-based encoders, they aren't supported by the PVR as much as the hardware cards are. Software cards use the CPU to encode the files and if you max out the CPU you can get stuttering and slowdowns.
The better your graphics card with TV-out the better. I use a nVIdia 5200 right now for my SDTV, but will probably get something like a 6800 when I upgrade to a HDTV.
You don't need to spend money on 10K HD's, P-ATA drives on 7200rpm are fine, some people even use the 5400rpm drives for less heat and noise. Spend your money on GB's. Plan on 1.5-3GB per hour of video for SDTV recordings, depending on what recording quality you require.