Having done semi-serious implementations of both, I disagree. Implementing IP and TCP and getting it hooked up to your OS so that your packets get spat out the network card and your responses get relayed back to your code is much harder than implementing a minimal TLS.

True. Minimal TCP with 1 MSS window may be easy, but proper congestion control with fast recovery, F-RTO, tail loss probe, SACK etc. is much harder. Miss one of these aspects and you get a TCP that takes minutes to recover from a lost packet in some obscure case. It took years to debug Linux TCP stack. Even BSD stack is already way behind.

Given that the context is "ability to type commands to a web server over telnet as a learning experience", I was of course talking about minimal implementations. TCP with congestion control is hard, just as TLS with proper compatibility is hard.

Yes: I was not including the difficulty of getting efficient congestion control implemented, but rather just the ability to deliver and receive TCP streams at all.