Acquisition of phonological processing skills, such as the ability to segment words into corresponding speech sounds, is critical to the development of efficient reading. Prior neuroimaging studies of phonological processing have often relied on auditory stimuli or print-mediated tasks that may be problematic for various theoretical and empirical reasons. For the current study, we developed a task to evaluate phonological processing that used visual stimuli but did not require interpretation of orthographic forms. This task requires the subject to retrieve the names of objects and to compare their first sounds; then, the subject must indicate if the initial sounds of the names of the pictures are the same. The phonological analysis task was compared to both a baseline matching task and a more complex control condition in which the participants evaluated two different pictures and indicated whether they represented the same object. The complex picture-matching condition controls for the visual complexity of the stimuli but does not require phonological analysis of the names of the objects. While both frontal and ventral posterior areas were activated in response to phonological analysis of the names of pictures, only inferior and superior frontal gyrus exhibited differential sensitivity to the phonological comparison task as compared to the complex picture-matching control task. These findings suggest that phonological processing that is not mediated by print relies primarily on frontal language processing areas among skilled readers.