It's interesting that the 114th Congress adjourned an hour before the 115th Congress convened by scheduling a "special legislative session" for the first week of January 2016, while Obama was still President for two more weeks. Prior Congresses had at least a week between the close of one and the start of another.
-PJ
The republicans would do a pro forma session about every three days and as long as a week, which historically, the tradition dictated that the Senate was not in recess. Obama made recess appointments anyway between these pro forma Senate sessions. The republicans in Congress sued and won a SC case a few years ago that stated pro forma sessions are indeed official sessions and having a reasonable number of days between sessions does not constitute a recess.