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What version of max are you using? I just saw this on Eat 3D yesterday..
If you're using Max9 then what you need to do is add an edit poly modifier in the stack under the cage modifier on the low poly mesh. Enter edit poly face mode, select all faces then click the hide button. Max 9 has a glitch where it won't let the light pass through the low poly mesh for AO bakes with MR. Hope this helps ya.
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